Sapura Fabrication Sdn Bhd & 3 Ors v Gas

Arbitration — Agreement — International — Enforcement of arbitration agreements; Conflict of laws — Choice of law — Insolvency — Recognition and enforcement of foreign insolvency proceedings — Submission to foreign insolvency proceedings; Insolvency Law — Cross-border insolvency — Recognition of foreign insolvency proceedings — Automatic moratorium arising on recognition as foreign main proceedings — Whether carve-out should be granted for arbitration to proceed — Article 20 UNCITRAL Model Law on Cross-Border Insolvency