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Ann: AVZI Successfully Defends Against Jin Cheng ICC Proceedings, page-239

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    Can an arbitration agreement be governed by a different law?
    CERTAINLY...!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

    Determining the Law: If the law governing the arbitration agreement is not specified, it depends on the circumstances of the case. Arbitral tribunals or national courts will consider factors such as the seat of arbitration and the approach taken to determine the applicable law.

    In summary, while the law governing the arbitration agreement can differ from the main contract, specifying it upfront ensures clarity and smoother dispute resolution processes......sneaky.png
 
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