“…agreement as to the seat of an arbitration is analogous to an exclusive jurisdiction clause”. These statements have been approved twice by this court, in C v D [2008] Bus LR 843, [17], perLongmore LJ and very recently in Minister of Finance v IPIC [2019] EWCA Civ 2080, [37], per Vos C.…”
“…t is the case even though the issue referred to arbitration is to be determined in accordance with the laws of another country (see C v D [2007] EWCA Civ 1282; [2008] Bus LR 843). Article V of the Convention sets out the only grounds on which enforcement of a foreign award may be refused. These include in art V(1)(e) that the award “ha…”