The law governing the arbitration agreement (here English law) determines whether a non-signatory is bound by that agreement, not the law of the main contract.
arbitration
A dispute must be referred to arbitration if it falls within the scope of the arbitration agreement, applying a generous interpretation in favour of arbitrability.
Enforcement of international commercial arbitral awards does not involve arbitrators exercising judicial power; enforcement itself is a judicial function constitutionally vested in Chapter III courts.
Court considered how the Guy Lam discretion operates where the existence of an arbitration agreement is itself in dispute.
Get a detailed analysis of Kabab-Ji SAL v Kout Food Group and how it applies to your situation.
Explain Kabab-Ji SAL v Kout Food Group