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Founded in 2012, Signature Litigation has grown into one of London’s pre-eminent specialist dispute resolution practices. From the outset, we set out to do things differently: a conflict-free, disputes-only platform designed to give clients the undivided focus and strategic agility that complex, high-stakes matters demand.
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Established in 2017, Signature Litigation's Gibraltar office was founded to address growing demand for specialist expertise in commercial litigation and private wealth disputes on the Rock.
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Signature Litigation AARPI houses one of France’s most enviable product liability practices, with the team also handling commercial and corporate litigation, insurance and reinsurance, toxic tort and ESG, civil fraud and asset tracing, international arbitration, administrative and public law.
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Frankfurt has emerged as one of Europe's foremost financial and commercial centres and, increasingly, as a bridge between European and Asian markets. With that growth comes an increasing demand for sophisticated dispute resolution. Signature Litigation established its Frankfurt office to meet this need, bringing our conflict-free, disputes-only platform to the German market.
FIND OUT MOREPartner Flore Poloni and Associate Thibaud Roujou de Boubée discuss two seemingly close decisions from the French and English Courts have recently revealed contrasting standards in the law applicable to an arbitration agreement in France and in the UK, in the Bulletin Rapide Droit des Affaires. Flore and Thibaud's article was published in Bulletin Rapide Droit des Affaires, 30 November 2020, and can be found here.
Two recent rulings handed down by the French and English courts in the case of Kabab-Ji S.A.L. v / Kout Food Group on June 23, 2020, have led to conflicting conclusions on the law applicable to the arbitration agreement. Additionally, on October 9, 2020, in the Enka v Chubb case, the UK Supreme Court set out the principles for determining the law applicable to an arbitration agreement in the absence of an express choice of law.
The article compares the two recent decisions in France (seat of the International Chamber of Commerce) and in England (seat of the International Court of Arbitration in London) which examined the approach adopted to determine the law applicable to an arbitration convention (namely Kabab-Ji SAL (Lebanon) v. Kout Food Group (Kuwait) [CA Paris, June 23, 2020, n ° 17/ 22943] and Enka v Chubb [2020] UKSC 38) on 9 October 2020.
