Arbitration Agreement, Choice of Law, English courts, Express choice, International arbitration, Law governing the arbitration agreement, Proper law of arbitration agreement
Hold on to Your Seats, Again! Another Step to Validation in Enka v Chubb Russia?
In the recent ruling of 29 April 2020, the England and Wales Court of Appeal, departing from Sulamérica, has held the seat of arbitration as an implied choice of the law of the arbitration agreement in cases where parties expressly chose the law applicable to the main contract and the seat of arbitration under a…