Arbitration Agreement Icc

The courts of Singapore have held that the applicable law of the main contract “is a strong indicator of the applicable law of the arbitration agreement, unless there are elements to the contrary” and that a choice of place of place of business other than the place of the applicable law of the main contract itself is not sufficient to move the starting point. Indeed, the courts of Singapore have repeatedly found that the implied choice of law governing the arbitration agreement is identical to the choice of law applicable to the main contract. It is recalled that it is necessary, under the laws of some countries, for contracting parties to explicitly accept arbitration clauses, sometimes in a precise and particular manner. .