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Arbitration Agreements France

White & Case LLP

Two courts confirm the logical limits of the validation principle

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Courts in Paris and The Hague have recently refused to enforce awards from the same arbitration. These decisions confirm the logical limits to the pro-arbitration principle that arbitrators and courts should seek to uphold...more

Akin Gump Strauss Hauer & Feld LLP

Fourth (and Final?) Act in the Kabab-Ji Saga—What Law Governs the Arbitration Agreement (Law of the Seat or Law of the Underlying...

On 28 September 2022, the French Cour de cassation upheld the French Court of Appeal’s decision in Kabab-Ji SAL v. Kout Food Group that the law of the seat, rather than the law governing the underlying contract, governed...more

A&O Shearman

Paris Arbitration Week Overview: Pathways to Justice and Peace for Ukraine

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On March 31, 2022, as part of the 2022 Paris Arbitration Week, Shearman & Sterling LLP and the Ukrainian Arbitration Association co-hosted a conference on “International Law and the War in Ukraine: The Path(s) to...more

WilmerHale

Kabab-Ji SAL (Lebanon) v Kout Food Group (Kuwait) [2021] UKSC 48: UK Supreme Court clarifies approach to determining whether there...

WilmerHale on

In an important recent decision, the U.K. Supreme Court provided further guidance on how to determine the law that applies to an international arbitration agreement. In its unanimous decision in Kabab-Ji SAL v Kout Food...more

Akin Gump Strauss Hauer & Feld LLP

The ‘Third Act’ in the Kabab-Ji Saga—What Law Governs the Arbitration Agreement (Law of the Seat or Law of the Underlying...

In a Judgement handed down on 27 October 20211, the UK Supreme Court upheld the English Court of Appeal finding in Kabab-Ji SAL v. Kout Food Group of 20 January 2020 that English law as the law governing the relevant...more

Akin Gump Strauss Hauer & Feld LLP

The Law of an Arbitration Agreement: Is it the Law of the Seat or the Law of the Underlying Contract? – Paris Contradicts London

If there is no express law of the arbitration agreement, the law with which that agreement has its closest and most real connection is either the law of the underlying contract or the law of the seat of the arbitration. In...more

Hogan Lovells

The Paris Court upholds the supranational nature of OHADA law in dismissing annulment application (CA Paris 16/25484, 20 December...

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The Paris Court of Appeals recently upheld an arbitral award applying OHADA law. The application to set aside the award had been brought by the State of Cameroon based on arguments made under Cameroonian law....more

Skadden, Arps, Slate, Meagher & Flom LLP

Employment Flash - June 2017

This edition examines recent labor and employment developments at the U.S. federal, state and local levels, including the House of Representatives' American Health Care Act and the Senate's Better Care Reconciliation Act, the...more

Hogan Lovells

Global Employment Law Update - April 2017

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In this edition of our Global Employment Law Update we look at the effects of the rapid growth of the "gig" economy across the jurisdictions. There have been significant case law and legislative responses, particularly on...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Employment Flash - October 2016"

Spotlight on Whistleblower Protections - On October 24, 2016, the Securities and Exchange Commission (SEC) issued a “risk alert” regarding SEC registrants’ compliance with Rule 21 F-17, which implements Section 21F of...more

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