Polar Opposites – French Cour de cassation and UK Supreme Court Apply Different Laws to Same Arbitration Agreement

By Diego Luis Alonso Massa, 25 October 2022

In a manner diametrically opposed to last year’s UK Supreme Court decision (involving the very same parties and arbitration agreement), France’s Cour de cassation ruled that under a material rule of international arbitration law, an arbitration clause is independent from the main contract in which it is contained, and that its existence,...
URL: https://taobserver.com/news/272/polar-opposites--french-cour-de-cassation-and-uk-supreme-court-apply-different-laws-to-same-arbitration-agreement