The proper law of the arbitration agreement. The significance to be attached to the choice of the seat of the arbitration. Court of Appeal in the Courts of England and Wales, Enka Insaat Ve Sanayi AS v OOO “Insurance Company Chubb” & Ors [2020] EWCA Civ 5: The United Kingdom Supreme Court, Enka Insaat Ve Sanayi AS v. OOO “Insurance Company Chubb” & Ors [2020] UKSC 38 (09.10.2020)