LNG Offshore Production and Regasification
CHAPTER 10
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Dispute resolution under English law contracts
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A Introduction
10.1 This book is concerned principally with contracts governed by English law. The type of contracts we consider – vessel construction, charterparties, management contracts and the like – are often made subject to English law, even though there may be no connection between the parties or the project with English jurisdiction. In such case, English law is not imposed by operation of law based on the jurisdiction,1 but by the choice of the contracting parties. They may also choose to make England the place for resolution of disputes arising under the contract, usually by choosing London arbitration. However, even though English law may govern the contract, it does not automatically follow that the forum for resolution of disputes is England. The parties may choose an alternative place which may be more convenient, but still retain English law as the governing law. The arbitrators may need to hear evidence as to the relevant English law applicable to the dispute, although often the arbitrators are English law qualified, particularly in jurisdictions such as Hong Kong or Singapore.