After the decision in Enka Insaat ve Sanayi A.S. v OOO Insurance Company Chubb, UK Supreme Court, in the absence of an express choice, to decide what is the governing law of an agreement to arbitrate in the context of a party’s attempt to enforce an arbitration award.
The U.K. Supreme Court recently handed down its long-awaited judgment in Kabab-Ji SAL (Lebanon) v Kout Food Group (Kuwait). The judgment confirmed and applied the principles concerning.