“…rent foreign law, English law applies. This was the application of the two general rules identified by Lord Leggatt JSC in Brownlie v FS Cairo (Nile Plaza) LLC [2021] UKSC 45; [2022] AC 995 at [108]-[112].…”
“…Again, this seems to me legitimate. Since the hearing before us the Supreme Court has analysed this topic in some depth in FS Cairo (Nile Plaza) LLC v Brownlie [2021] UKSC 45, [2021] 3 WLR 1011. As Lord Leggatt put it at [149], “[t]he essential point is that the presumption of similarity is only ever a basis for drawing inferences a…”