STAR REEFERS POOL INC v JFC GROUP LTD
[2011] 2 Lloyd's Rep. 215
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 England appropriate forum — Rome Convention, article 3.