Serious irregularity: ad hoc agreement to arbitrate

In Union Marine Classification Services LLC v The Government of the Union of Comoros and Another (No 2) [2017] EWHC 2364 (Comm) a challenge was made to an arbitration award on the ground that the issue resolved by the arbitrator had not been a part of the original submission to arbitration. HHJ Waksman QC ruled that the parties had agreed to ad hoc arbitration on the point.

Union Marine : the facts