UK Supreme Court Looks to Restatement of U.S. Law of International Commercial and Investor-State Arbitration

The Court found that when choice of law is not identified in an arbitration agreement, the law of the seat of arbitration is the law “most closely connected” to agreement, and references Restatement of the Law, The U.S. Law of International Commercial and Investor-State Arbitration in support of its decision.

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