Paris seat doesn’t disturb choice of English law, says appeal court
Court of Appeal of England and Wales, Royal Courts of Justice (Credit: Shutterstock/Alexandre Rotenberg)
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.
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