To print this article, all you need is to be registered or login on Mondaq.com. A decision of the Supreme Court, the final court of appeal for civil cases in the United Kingdom, has clarified how the governing law of an arbitration agreement is to be determined when the law applicable to the contract containing it differs from the law of the "seat" of the arbitration. Background The case arose out a fire at a power plant in Russia. Chubb had insured the owner of the power plant against such damage. The owner had engaged a contractor to carry out construction