Conflict of laws
The UK Supreme Court has confirmed the longstanding power of the courts to enjoin foreign proceedings that violate a contractual arbitration provision -- even in circumstances where no arbitration is on foot or in contemplation: Ust-Kamenogorsk Hydropower Plant JSC v AES Ust-Kamenogorsk Hydropower Plant LLP, [2013] UKSC 35. The parties in that litigation had agreed to refer disputes about a hydro plant in Kazakhstan to arbitration in London. When a dispute did arise, the Kazakhstan government obtained an order from a court in that country declaring the arbitration clause invalid. (There may be a Borat joke to make here, but we won't go there.) The respondent LLP applied to the English courts for a declaration that the clause was valid and a stay of the proceedings in Kazakhstan.
http://www.bailii.org/uk/cases/UKSC/2013/35.html
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