Articles

Competing Arbitration Clauses in Multi-Contract Transactions: the “Centre of Gravity” Approach in XX and Ors v ZZ

Where commercial relationships are governed by multiple related contracts, each containing its own arbitration clause, disputes may arise as to which clause should govern a given claim. This issue becomes particularly significant in investment structures where different agreements are executed at different stages and involve overlapping parties and obligations. The High Court of Hong Kong […]

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The Fatality of Misnaming Arbitral Institutions under PRC Law

Arbitration clauses are often described as the root of international contracts, however their effectiveness depends heavily on precise drafting. Even minor errors, such as the misnaming of an arbitral institution can raise questions about enforceability and, in some jurisdictions, may completely undermine the parties’ agreement to arbitrate. ‎‎In such a case, courts across different jurisdictions

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