“…This is well established law and is clearly set out and summarised by Lord Collins in Vizcaya Partners Ltd v Picord [2016] UKPC 5, [2016] 3 All ER (Comm) 181 at [60]:…”
“…, see King v Brandywine Reinsurance Co (UK) Ltd [2005] EWCA Civ 235, [2005] 2 All E.R. (Comm) 1 at [68] para 68 per Waller LJ and Vizcaya Partners Ltd v Picord [2016] UKPC 5; [2016] Bus LR 413, para 60 per Lord Collins. It is not to have competing arguments as to how the highest court in the foreign jurisdiction would decide the qu…”