Conflict of law

Trafigura Beheer BV v Kookmin Bank Co [2006] EWHC 1921 (Comm)

The English court had held that English law governed a letter of credit and the claims by the defendant Korean issuing bank against the beneficiary under the letter of credit. The claimant applied for an anti-suit injunction to restrain proceedings by the defendant in Korea seeking to persuade the Korean court to apply Korean law to the letter of credit and to reach a perverse construction of the letter of credit.