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Singapore
Leading Case
proper law of arbitration agreementarbitration agreementsseparability
BCY v BCZ
[2017] 3 SLR 357
Key Principle
Where parties have not expressly chosen the law of the arbitration agreement, the proper law follows the proper law of the main contract, subject to the seat displacing it where necessary; the arbitration agreement is separable but not isolated.
Area of Law
Arbitration — proper law of arbitration agreement — separability
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