Chiann Bao moderated a roundtable discussion at the joint ICC DRS and ICC United Kingdom conference during the 26th IBA Annual Arbitration Day in London

3 April 2025

Chiann moderated a panel that explored the legal principles governing arbitration agreements, focusing on the contrasting approaches taken by the UK Supreme Court and the French Cour de Cassation in Kabab-Ji v. Kout Food.

The discussion analysed how each court determined the applicable law and the broader implications of these rulings for the validity and enforceability of arbitration agreements, and provided insights into the challenges of legal certainty in international arbitration and the practical consequences for parties navigating cross-border disputes.

ICC - Clash of Legal Perspectives: Views on the law governing arbitration agreements in the UK and France

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