“…e authorities on section 73, of which the most important were Rustal Trading Ltd v Gill & Duffus SA [2000] 1 Lloyd’s Rep 14; JSC Zestafoni v Ronly Holdings Ltd [2004] EWHC 245 (Comm), [2004] 2 Lloyd’s Rep 335; The Ythan [2005] EWHC 2399 (Comm), [2006] 1 Lloyd’s Rep 457; Habas Sinai ve Tibbi Gazlar Istihsal Endustrisi AS v VSC Steel Co Ltd […”
“…oing so far as to suggest the doctrine insulates the arbitration agreement for all purposes (cf JSC Zestafoni G Nikoladze Ferroalloy Plant v Ronly Holdings Ltd [2004] EWHC 245 (Comm)), there are good reasons for treating it as doing so for the purposes of choice of AA law where there is a different curial law from that applicable to the mai…”