“…He then considered (at [38]-[41]) the decision of the House of Lords in Channel Tunnel Group Ltd v Balfour Beatty Construction Ltd [1993] AC 334, in which the parties had agreed on ICC arbitration in Brussels. Lord Mustill said that it was possible in principle to claim an interim injunction in support …”
“…Starting with Channel Tunnel v Balfour Beatty Ltd [1993] AC 334, there is a good deal of authority to support the proposition that the court has the inherent power to stay proceedings which have been brought in breach of a …”
“…oted above and concluded that it was unaffected by anything which that judge said as Lord Mustill in Channel Tunnel Group Ltd v Balfour Beatty Construction Ltd [1993] AC 334. He said at paragraph [22] that the AA law was more likely to be that of the law of the seat of the arbitration than the law of the main contract, giving his r…”
“…en the law of the ‘host’ agreement and the law of the seat of the arbitration. He cited what Lord Mustill said in Channel Tunnel Group Ltd v Balfour Beatty Ltd [1993] AC 334 at 357-8, that it would be exceptional for the proper law of the arbitration agreement to be different from an express choice of law for the host contract. The…”