The ongoing Kout Food saga provides a salutary reminder that difficult issues can sometimes arise when parties choose different systems for the substantive law of their contractual relationship and the curial law of the seat...more
7/13/2020
/ Appeals ,
Arbitral Authority ,
Arbitration Awards ,
Choice-of-Law ,
Contract Terms ,
Court of Cassation ,
Enforcement of Foreign Judgments ,
France ,
Franchises ,
Jurisdiction ,
Non-Signatories ,
Split of Authority ,
UK ,
UK Supreme Court