Should Naming the Arbitral Seat not be Enough?

By Jeremy Hernandez-Lum Tong In 2020 and 2021, the Supreme Court of the United Kingdom (“UKSC”) made two seminal decisions on the law governing arbitration agreements, namely Enka Insaat Ve Sanayi AS v OOO Insurance Company Chubb and Kabab-Ji SAL v Kout Food Group. The latter, Kabab-Ji UKSC, recapitulated the reasoning in Enka, but differed…