The concept of transnational issue estoppel is well established under English law. Until recently, English courts had not yet had occasion to consider whether transnational issue estoppel could apply in the context of the...more
3/10/2025
/ Arbitration ,
Arbitration Awards ,
Enforcement Actions ,
Estoppel ,
International Arbitration ,
Investors ,
Jurisdiction ,
Russia ,
State Immunity Act 1978 (the SIA) ,
The Hague ,
UK
On 9 October 2020, the U.K. Supreme Court in Enka Insaat Ve Sanayi AS v. OOO Insurance Company Chubb [2020] UKSC 38 ruled on the English law approach to determining the law governing an arbitration agreement. The Supreme...more