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United Kingdom
Leading Case
uncategorized
Sulamerica Cia Nacional de Seguros SA v Enesa Engenharia SA
[2012] EWCA Civ 638; [2013] 1 WLR 102; [2012] 2 All ER (Comm) 795
Key Principle
The proper law of an arbitration agreement is determined by a three-stage inquiry – express choice, then implied choice, then the system of law with which the arbitration agreement has its closest and most real connection – and is not necessarily the same as the law governing the main contract.
Area of Law
a
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