When the Governing Law and Arbitration Clause Don't Align | Delphine Ghighi & Linda Jaques

Описание: In this episode of LA Marine Global Currents, we’re joined by Delphine Ghighi, Partner at Tal & Co, to discuss why the law governing an arbitration agreement can have a major impact on dispute outcomes and award enforcement.

Using the Kabab-Ji SAL v Kout Food Group ([2021] UKSC 48) case as a practical example, we explore the approach of the French courts, when the governing law of a contract and the seat of arbitration differ.

Tune in for practical drafting tips on reducing uncertainty, avoiding parallel proceedings, and ensuring arbitration clauses are fit for purpose in cross-border contracts.

Key takeaway: Don’t treat arbitration clauses as boilerplate. Clear drafting today could save years of costly litigation tomorrow.
Need expert support in this area? Contact LA Marine or Tal & Co today.

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