Torn Between Sulamérica and FirstLink? A Practical Solution to Choice of Law Issues at the Pre-Award Stage - Asian Dispute Review View Torn Between Sulamérica and FirstLink? A Practical Solution to Choice of Law Issues at the Pre-Award Stage by - Asian Dispute Review Torn Between Sulamérica and FirstLink? A Practical Solution to Choice of Law Issues at the Pre-Award Stage 18 1

This article discusses the Sulamérica and FirstLink decisions of, respectively, the courts of England & Wales and Singapore. It draws attention to the different approaches adopted with regard to the choice of law governing international arbitration agreements and suggests, from an in-house counsel’s viewpoint, a practical solution founded on a more faithful construction of the New York Convention.

Asian Dispute Review