One of the most notable reforms is the new default rule that, in the absence of an express agreement between the parties on the law governing the arbitration agreement, it is the law of the seat that applies. The Act states...more
The High Court rejected an application by the Republic of Korea to set aside an investment arbitration award under s67 Arbitration Act 1996. In deciding that the arbitrators had substantive jurisdiction, Butcher J scrutinised...more