The Supreme Court (by a majority) has upheld the decision of the Court of Appeal that an arbitration agreement between Enka Insaat Ve Sanayi AS (Enka) and OOO Insurance Company Chubb (Chubb Russia) was governed by English law (the law of the seat of arbitration) and that it was appropriate to grant an anti-suit injunction (ASI) to restrain Chubb Russia from pursuing a claim brought in the Russia courts. Despite upholding the Court of Appeal's ultimate decision, the Supreme Court disagreed with the approach taken by the Court of Appeal as to the existence of a 'strong presumption', in the absence of express party agreement, that a choice of seat implied a choice of the curial law to govern the arbitration agreement. The Supreme Court confirmed that under English law, the law governing the arbitration agreement is either (a) the law chosen by the parties to govern it expressly...