“…that Iranian law does not contain any principle, equivalent to the Fiona Trust principle in English law (Fiona Trust & Holding Corpn v Privalov [2007] UKHL 40, [2007] Bus LR 1719), that an arbitration agreement should be interpreted so as to include any dispute arising out of the relationship between the parties, regardless of verbal di…”
“…ions. It is not a result that, objectively, parties are likely to have intended. As Lord Hoffmann said in Fiona Trust & Holding Corp v Privalov [2007] UKHL 40, [2007] Bus LR 1719 at [13]:…”
“…The Judge referred to Lord Hoffmann’s observations in Fili Shipping Co Ltd v Premium Nafta Products Ltd [2007] UKHL 40, [2007] Bus LR 1719, at [5] – [8] and [13] about the interpretation of arbitration agreements. In that case Lord Hoffmann emphasised the need for the court to give effect, so far …”