ABSTRACT
Express choice of law As a matter of English law, the Rome I Regulation on the Law Applicable to Contractual Obligations,1 provides that:
In most shipbuilding projects, the parties will select as the governing law of the contract the law of the chosen place of arbitration. This is nevertheless not mandatory and the parties may occasionally agree upon a choice of national law (e.g., English law) and a distinct jurisdiction for the resolution of disputes (e.g., Singapore). Where, however, a different law has been agreed from the law of the place of dispute resolution (the so-called ‘‘forum’’), it will normally still be for the procedural laws of the forum to determine the method and processes by which the dispute is to be resolved.
