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...Michaelmas term uksc on appeal from ewca civ judgment enka insaat ve sanayi as respondent v ooo insurance company chubb appellant before lord kerr sales hamblen leggatt burrows given october heard and july david bailey qc robin dicker toby landau joseph marcus mander niranjan venkatesan clara benn instructed by kennedys shearman law llp london sterling with whom agrees i introduction where an international commercial contract contains agreement to resolve disputes arbitration at least three systems of national are engaged when a dispute occurs they the governing substance arbitrate process is generally applicable which has arisen sometimes referred curial seat usually place chosen for in these two may differ each other also governs validity scope central issue this concerns system containing it differs long divided courts commentators both country internationally one side there those who say that should govern though separable forms part have been court decisions falling either divide ...