Has the English Court of Appeal Changed its Mind on the Proper Law of the Arbitration Agreement?

Abstract

The case of Sulamérica CIA Nacional de Seguros SA and others v Enesa Engenharia SA and others [2012] EWCA Civ 638 (“Sulamérica”) was of significant relevance to the arbitration world as it set down a clear 3-limb test for determining the law g