Trecho do comentário: "This is a case comment on the recent Supreme Court’s case Enka Insaat Ve Sanayi AS v. OOO 'Insurance Company Chubb' & Ors [2020] UKSC 38 (Enka v. Chubb), which is now the most crucial authority in English law on the law applicable to the arbitration agreement.
It is not common practice for arbitration clauses to have an express
mandate regarding the governing law of the arbitration agreement; nonetheless, finding a clear direction can be even more challenging in less well-written provisions."

I The Judgment -- Introduction -- X Conclusions on applicablelaw -- XII Overall conclusion -- LORD BURROWS: (dissenting) (with whom Lord Salesagrees) II Commentary -- Introduction -- Setting thescene: thelaw ofthearbitration agreement -- The law applicable to the arbitration agreement in Enkav. Chubb -- CONCLUSION