5 There are therefore only three different points of connection, the seat which is the strongest of them with regard to the determination of the law which governs all aspects of the validity of international arbitration agreements for six different legal issues (see points 2 and 4) of different legal issues. 1 The validity of the arbitration agreement is above all in accordance with the law chosen by the parties. As a general rule, international commercial contracts do not contain specific clauses of choice for the arbitration agreement contained in those contracts. The general choice clause of the law contained in the contract, which establishes the law of the contract, does not necessarily apply to the arbitration agreement, which is a separate contract. In the appeal process, the Court of Appeal set aside that decision. He assumed that an arbitration agreement without a party election should be governed by the law of the arbitral tribunal (in this case English law); That the Russian procedure violated the arbitration agreement; and that insurers should be prevented from pursuing the Russian procedure. The Court of Appeal therefore issued a publication ban. In Sulamérica, a dispute aeddle was over insurance contracts for a hydroelectric power plant in Brazil. The English court had to decide whether Brazilian or English law was considered the applicable right of the arbitration agreement.

In the absence of an explicit agreement, the Tribunal first considered whether an existing right could be underestimated. Article 1 specifies that the “this agreement” (capitalized) contains all the contractual terms established at the time, including Article 14. Since Article 15 provides that “this agreement is regulated and interpreted in accordance with the laws of England,” it specifies that all provisions of the agreement, including Article 14, are governed by English law. The response to the proposition that, if this analysis were correct, an explicit choice of the existing law of the compromise clause would be given in any contract containing a rule clause, essentially that of Andrew Smith J in Arsanovia [22]. The existing legal clauses do not necessarily cover the arbitration agreement. This is due to the correct design of Articles 1 and 15. The concept of “dissociability” from arbitration agreements is associated with this. Most modern national arbitration laws (including England, Wales and Northern Ireland, the Arbitration Act 1996) recognize dissiability, i.e. an agreement to subject disputes to arbitration can be considered a separate agreement for certain purposes, even if it is part of a broader contract. In the absence of this notion of dissociability, any dispute (legitimate or otherwise) over the existence or validity of the principal contract would, by definition, jeopardize the existence of the arbitration agreement it contains, potentially compromising the agreed dispute resolution mechanism, give rise to satellite disputes and could leave the parties in the absence of appropriate means to resolve disputes.