ICC Case No. 6281
International Chamber of Commerce International Court of Arbitration
15 Y.B. Comm. Arb. 96-101 (1990)
- Written by Rich Walter, JD
Facts
A buyer (plaintiff) with ties to Egypt and France entered into a sales contract with a Yugoslavian seller (defendant). The contract was signed in Yugoslavia. When a contract dispute arose, the buyer invoked the contract’s arbitration clause and referred the dispute to the International Chamber of Commerce International Court of Arbitration. The clause did not specify which country’s substantive law would control the dispute’s outcome. Although Egypt, France, and Yugoslavia all had ratified the United Nations Convention on Contracts for the International Sale of Goods (CISG), the CISG was not in force when the parties’ dispute arose. The arbitrator determined that the private international law of all three countries would resolve the dispute in light of Yugoslavia’s substantive law.
Rule of Law
Issue
Holding and Reasoning ()
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