News

     

Paris Court of Appeals (on 23 June 2020, RG No. 17/22943) and the UK Supreme Court (on 9 October 2020, [2020] UKSC 38)

By Signature Litigation
Back to News

Author:

Signature Litigation

Cross channel perspectives on the law applicable to the arbitration agreement.

The law applicable to the arbitration agreement can be revealing of contrasting legal cultures: French Courts apply a substantive rule, while UK Courts use the “closest connection test”.

This was made clear almost simultaneously by the Paris Court of Appeals (on 23 June 2020, RG No. 17/22943) and the UK Supreme Court (on 9 October 2020, [2020] UKSC 38).

 

Latest news

All news