Chaos Amidst Order: Arbitrating Disputes Involving

This article explores the English Court of Appeal's judgment in the case of UniCredit Bank GmBH v. RusChem Alliance LLC. It explores the court's interpretation of the law applicable to the parties' arbitration agreement and the loopholes within the same. This issue, while a classical tug of war between the law of the seat and the law of the main contract, poses fresh challenges as it arose with respect to the jurisdictional competence of English courts to grant an anti-suit injunction against the Respondents from pursuing proceedings before the Russian Arbitrazh Court, in light of their agreed upon Paris seated arbitration. This issue becomes complicated due to the newly imposed sanctions upon Russia and its response to the same, by virtue of which, exclusive jurisdiction for disputes with such sanctioned entities has come to vest exclusively in the Arbitrazh Court. While the Court of Appeal granted the said injunction, there appear to be multiple gaps in the