ENKA INSAAT VE SANAYI AS v OOO “INSURANCE COMPANY CHUBB”
[2020] 2 Lloyd's Rep. 449
SUPREME COURT
Before Lord Kerr,Lord Sales,Lord Hamblen,Lord Leggatt,Lord Burrows
Arbitration – Law applicable to arbitration agreement – Whether applicable law followed that of the substantive agreement or that of the seat – Anti-suit injunction – Senior Courts Act 1981, section 37 – Arbitration Act 1996, sections 4(5), 7 and 103 – Rome I Regulation, Regulation (EC) No 593/2008.