“…A similar approach has been adopted in Singapore. In BCY v BCZ [2016] SGHC 249, [2016] 2 Lloyd’s Rep 583 the parties were negotiating an agreement for the sale of shares. Their negotiations were expressed to be subject to the execution of a mutually acceptable agr…”
“…The judge said at [16] that, however, Steven Chong J in the High Court of Singapore in BCY v BCZ [2016] 2 Lloyd’s Rep 583 at [65] had said that, adopting Sulamerica: “the governing law of the main contract is a strong indicator of the governing law of the arbitration agreement unl…”