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The decision in the case of Kabab-Ji vs Kout Food issued on 28 September 2022 by France’s highest Court brings into particularly sharp focus the French and English court’s differing. ....
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. ....