Tag Archives: governing law

Case Update: Seat of Arbitration and Implied Choice of Governing Law of Arbitration Agreement

[Update: the paragraphs on the Singapore High Court’s analysis of the arbitration clause and its implications has been updated to more closely reflect the language at paragraph [17] of the Singapore High Court’s decision.]  A party may rely on a valid … Continue reading

Posted in Arbitration, Singapore, UK | Tagged , , , , , , , , , , , , , , , | 2 Comments

Singapore Law Gazette – Arbitration in Singapore 2013: A Year in Review

We are pleased to announce that the Singapore Law Gazette has just published an exclusive article that we recently wrote for them. The article Arbitration in Singapore 2013: A Year in Review is now available online. As we enter 2014, … Continue reading

Posted in Arbitration, Hong Kong, Indonesia, Malaysia, Singapore, UK | Tagged , , , , , , , , , , , , | Leave a comment

Case Update: (1) Governing law of the arbitration agreement determines scope of arbitrability; (2) Disputes on bills of exchange fall within arbitration clause

We had previously discussed the case of Piallo GmbH v Yafriro International Pte Ltd, [2013] SGHCR 20 (“Yafriro (AR)”). The issue was whether a claim on certain dishonoured cheques paid pursuant to a Distributorship Agreement could avoid a stay of court … Continue reading

Posted in Arbitration, Hong Kong, Singapore, UK | Tagged , , , , , , , , , | 2 Comments

Case Update: (1) Lack of substantive jurisdiction in respect of one respondent affects award as against the other respondent; (2) Substantive jurisdiction not affected by finding of liability under a different agreement

The English High Court in Arsanovia Ltd & Ors v Cruz City 1 Mauritius Holdings, [2012] EWHC 3702 (Comm) has delivered a relatively short but dense decision dealing with a number of issues revolving around the issue of different governing … Continue reading

Posted in Arbitration, India, UK | Tagged , , , , , , , , | 2 Comments

Technology and Outsourcing Hot Spots Series (5): Multi-Tier and Unilateral Arbitration Clauses

In Part 4 of our Technology and Outsourcing Hot Spots Series, we considered how a properly drafted dispute resolution clause can give parties an appropriate dispute resolution mechanism which allows for an enforceable decision and avoids costly and time consuming … Continue reading

Posted in Arbitration, Asean, China, India, Singapore, UK | Tagged , , , , , , , , , | 4 Comments

Technology and Outsourcing Hot Spots Series (4): ADR and Dispute Resolution Clauses

Managing Disputes at the Drafting Stage In Part 1 of this Technology and Outsourcing Hot Spots series, we mentioned the importance of managing disputes from as early as the contract drafting stage. We considered that parties should ensure an accurate … Continue reading

Posted in Arbitration, Asean, China, India, UK | Tagged , , , , , , , | 4 Comments