Most contracts involving parties located in different countries
include provisions relating to the choice of a particular forum for
dispute resolution and identify the law to be applied.
The choice of law clause is intended as a means of achieving
certainty on the legal niceties applicable to the performance of
the parties' respective obligations and this is clearly a goal
which all contracting parties share. This provision singles out the
so-called "proper law" of the contract.
Much has been written about the desirability, in some instances,
of arbitration over formal court proceedings, and some parties view
arbitration as a preferable forum for the adjudication of all
potential disputes arising from their contract. It is accordingly
not uncommon for parties to select arbitration as their agreed
forum, in the event of a dispute arising. The dispute resolution
clause often goes further than the selection of arbitration over
ordinary court process, since these
