“…The decision of Mr Justice Andrew Smith in Arsanovia Ltd v Cruz City 1 Mauritius Holdings [2012] EWHC 3702 (Comm), [2013] 2 All ER Comm 1 is to the same effect. Although the contract in this case was governed by Indian law, there was no suggestion that Indian law differed …”
“…[2012] EWHC 3702 (Comm); [2013] 1 Lloyd’s Rep 235 at [21]: “The governing law clause is, at the least, a strong pointer to their intention about the law governing the arbitration agre…”