A contract was negotiated in London, but the contract did not state which law governed the agreement. However, it was accepted practice of the parties that English law governed their contracts. When dispute arose, the arbitration took place in Scotland under Scottish law. It was argued that even though English law governed contract between the parties, procedural law of the arbitration was Scottish law because parties brought their arbitration proceedings in Scotland and whole proceedings were conducted under Scottish law. This shows that there might be different law applicable to the contract and to the arbitration proceedings.
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