Lloyd's Law Reports Plus

Professor Robert Merkin KC; Dr Johanna Hjalmarsson

Document

ENKA INSAAT VE SANAYI AS v OOO “INSURANCE COMPANY CHUBB”

[2020] Lloyd's Rep. Plus 97

SUPREME COURT

Before Lord Kerr, Lord Sales, Lord Hamblen, Lord Leggatt and Lord Burrows

Arbitration – Law applicable to arbitration agreement – Whether applicable law followed that of the substantive agreement or that of the seat – Anti-suit injunction – Senior Courts Act 1981, section 37 – Arbitration Act 1996, sections 4(5), 7 and 103 – Rome I Regulation, Regulation (EC) No 593/2008.

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