Reinsurance: conflict of laws

The question in Axis Corporate Capital UK Ltd v Absa Group Ltd [2021] EWHC 225 (Comm); [2021] Lloyd’s Rep IR 195 was whether a group of admittedly poorly drafted choice of law and jurisdiction clauses in a tower of reinsurance agreements operated to confer exclusive jurisdiction on the English courts such as to justify the grant of anti-suit relief to restrain the reinsured from proceeding in the South African courts.

Axis : the facts