I am looking for cases where courts or tribunals have applied the three step approach (established in the Sulamerica case) to determine the law governing the arbitration agreement.

I have found instances in English and Singapore case law, but I am interested if other countries also use this method, especially in the civil law systems. Unfortunately, I cannot find any information on this topic.

Thank you in advance!

  • I found this in the Frence Civil Code of Proceedures – George White Mar 25 at 2:16

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