Sapura Offshore Sdn Bhd & 3 Ors

Conflict of laws — Recognition and enforcement of foreign insolvency proceedings — Submission to foreign insolvency proceeding; Arbitration — Arbitration agreements — Enforcement of arbitration agreements — Art II(3) Convention on the Recognition and Enforcement of Foreign Arbitral Awards Concluded at New York on 10th June 1958; 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 — Art 20 UNCITRAL Model Law on Cross-Border Insolvency