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Singapore court reconsiders the test for determining the implied choice of law governing arbitration agreement (BCY v BCZ)

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Published on: 21 November 2016

Published by a LexisNexis Arbitration expert

Table of contents

Original news
What is the issue which BCY v BCZ addresses?
Foundations for the legal analysis—Sulamérica
Practical implications
Practical tip—quick fix

Article summary

Arbitration analysis: Angeline Welsh of Matrix Chambers considers the Singapore High Court’s decision in BCY v BCZ which revisited the test for implying the governing law of an arbitration agreement. The Singapore High Court preferred the approach of the English Court of Appeal in Sulamérica Cia Nacional De Seguros SA and others v Enesa Engenharia SA to that of the Singapore High Court in FirstLink v GT Payment.

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