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In the latest decision in the Prestige saga, the English Court of Appeal has made two notable findings: it has refused to enforce a Spanish judgment on the basis that it would be contrary to public policy because it conflicts...more
On November 6, 2024, the French Supreme Court rejected the enforcement of an interim award on jurisdiction in the legal saga opposing Malaysia to the heirs of the Sultan of Sulu and spanning several jurisdictions. The Supreme...more
Courts in Paris and The Hague have recently refused to enforce awards from the same arbitration. These decisions confirm the logical limits to the pro-arbitration principle that arbitrators and courts should seek to uphold...more
If there is no express law of the arbitration agreement, the law with which that agreement has its closest and most real connection is either the law of the underlying contract or the law of the seat of the arbitration. In...more