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Day 5 of Signature’s Slide Show series – Enka Supreme Court decision

By Signature Litigation
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Signature Litigation

In its Enka decision of 9 October 2020, the UK Supreme Court clarified the law applicable to the arbitration agreement.

In a nutshell, in England, the conflicts of law rule is a closest connection test. The law with the closest connexion to the arbitration agreement will apply.

In France, a substantive rule is applied, as reminded by the KFG decision of 23 June 2020.

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