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Paris seat doesn’t disturb choice of English law, says appeal court

Jack Ballantyne and Sebastian Perry

24 January 2020

In what some warn may be a repeat of the famous Dallah case, the Court of Appeal in London has refused to enforce an ICC award in a Paris-seated dispute over a Middle Eastern food franchise after finding that English and not French law applied to the question of whether the debtor was bound by the arbitration agreement.