Singapore | The importance of stating the law of the arbitration agreement

Generally, there are at least three systems of law engaged in an arbitration: (i) the law which governs the substance of the dispute, (ii) the law of the chosen seat of the arbitration, and (iii) the proper law of the arbitration agreement. It is the last of these which is often overlooked but it is of no less importance.
 
In this update, we highlight the reasons and discuss the recent significant case of the UK Supreme Court in Enka Insaat Ve Sanayi A.S. v OOO Insurance Company Chubb [2020] UKSC 38.

Please click here to read more about the update.