STAR REEFERS POOL INC v JFC GROUP LTD
[2011] Lloyd's Rep Plus 51
QUEEN’S BENCH DIVISION (COMMERCIAL COURT)
Before Mr Justice Andrew Smith
Conflict of laws - Jurisdiction - Applicable law of contract - Claimant owners bringing claim against Russian guarantor of charterparty expressly governed by English law - Guarantor not party to charterparty - Guarantee not providing for any express choice of law - Whether good arguable case that guarantee governed by English law - Whether English court appropriate forum - Rome Convention, article 3.