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Kabab-Ji and the Law of the Arbitration Agreement: French and English Courts Clash Once Again
9 July 2020
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On 23 June 2020, the Paris Court of Appeal upheld a Paris-seated arbitration award between Kabab-Ji SAL and Kout Food Group that the English Court of Appeal had refused to enforce six months earlier on the grounds that the tribunal had wrongly asserted its jurisdiction.
Applying different laws to the question of whether or not Kout Food Group was party to the arbitration agreement, the Paris Court of Appeal held that it was a party, while the English Court of Appeal held that it was not.
The divergence highlights the importance of stipulating the law governing the arbitration agreement, as well as making clear the parties’ intentions regarding non-signatories.
Arbitration & International Disputes
Regional & Other Practices
Commercial Arbitration in Europe
Lord Goldsmith KC
Antoine F. Kirry
Ina C. Popova
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