Ascertaining the proper law of an arbitration agreement: The artificiality of inferring intention when there is none
The common law choice of law principles for determining the proper law of an arbitration agreement previously thought to be settled by the English Court of Appeal’s decision in Sulamérica v. Enesa [2013] 1 W.L.R. 102 have now been thrown into disarray after a recent string of three judgments: start...
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Main Authors: | CHAN, Darius, TEO, Jim Yang |
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Format: | text |
Language: | English |
Published: |
Institutional Knowledge at Singapore Management University
2020
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Online Access: | https://ink.library.smu.edu.sg/sol_research/3200 https://ink.library.smu.edu.sg/context/sol_research/article/5158/viewcontent/JOIA_37_0504.pdf |
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Institution: | Singapore Management University |
Language: | English |
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