The proper law of the arbitration agreement governs its validity, interpretation and effect1. That proper law is determined in accordance with the general principles of the conflict of laws, namely the law chosen by the parties or, in the absence of such choice, the law of the country with which the agreement is most closely connected2. An agreement to submit future disputes to arbitration usually forms part of a substantive contract, for example a contract of sale, but is to be treated as a separate contract3.
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