Dallah: Agreement Or Disagreement Between The English And French Courts? | White & Case LLP International Law Firm, Global Law Practice
Dallah: Agreement Or Disagreement Between The English And French Courts?

Dallah: Agreement Or Disagreement Between The English And French Courts?

Robert Wheal and Paul Brumpton examine the Dallah decisions in the UK Supreme Court and the Paris Court of Appeal. In these two cases, the courts came to different conclusions as to whether a non-signatory to an arbitration agreement should be considered a party to that arbitration agreement under French law. As a result, the UK Supreme Court refused to enforce the arbitral award in question, whereas the Paris Court of Appeal refused to annul the same arbitral award in France.

Click here to download PDF.