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International Arbitration Arbitration Agreements France

Hogan Lovells

Reforming French Arbitration Law: the proposal for a unified arbitration code

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Paris has been a leading arbitration hub for decades and French Arbitration law has had a great influence in the development of international arbitration around the world. On 20 March 2025, a working group chaired by...more

Foley Hoag LLP

Report on French Arbitration Law Reform

Foley Hoag LLP on

Key Takeaways: In March 2025, the French Ministry of Justice released the report of its Working Group on modernizing French arbitration law. This is the first major reform proposal since 2011. France is a leading seat of...more

A&O Shearman

The Prestige saga - clarifications on enforcement and State immunity from injunctions

A&O Shearman on

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

Akin Gump Strauss Hauer & Feld LLP

Fourth (and Final?) Act in the Kabab-Ji Saga—What Law Governs the Arbitration Agreement (Law of the Seat or Law of the Underlying...

On 28 September 2022, the French Cour de cassation upheld the French Court of Appeal’s decision in Kabab-Ji SAL v. Kout Food Group that the law of the seat, rather than the law governing the underlying contract, governed...more

A&O Shearman

Paris Arbitration Week Overview: Pathways to Justice and Peace for Ukraine

A&O Shearman on

On March 31, 2022, as part of the 2022 Paris Arbitration Week, Shearman & Sterling LLP and the Ukrainian Arbitration Association co-hosted a conference on “International Law and the War in Ukraine: The Path(s) to...more

WilmerHale

Kabab-Ji SAL (Lebanon) v Kout Food Group (Kuwait) [2021] UKSC 48: UK Supreme Court clarifies approach to determining whether there...

WilmerHale on

In an important recent decision, the U.K. Supreme Court provided further guidance on how to determine the law that applies to an international arbitration agreement. In its unanimous decision in Kabab-Ji SAL v Kout Food...more

Akin Gump Strauss Hauer & Feld LLP

The ‘Third Act’ in the Kabab-Ji Saga—What Law Governs the Arbitration Agreement (Law of the Seat or Law of the Underlying...

In a Judgement handed down on 27 October 20211, the UK Supreme Court upheld the English Court of Appeal finding in Kabab-Ji SAL v. Kout Food Group of 20 January 2020 that English law as the law governing the relevant...more

Akin Gump Strauss Hauer & Feld LLP

The Law of an Arbitration Agreement: Is it the Law of the Seat or the Law of the Underlying Contract? – Paris Contradicts London

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

Hogan Lovells

The Paris Court upholds the supranational nature of OHADA law in dismissing annulment application (CA Paris 16/25484, 20 December...

Hogan Lovells on

The Paris Court of Appeals recently upheld an arbitral award applying OHADA law. The application to set aside the award had been brought by the State of Cameroon based on arguments made under Cameroonian law....more

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