The Singapore Court of Appeal recently reversed the ruling of the Singapore High Court in BNA v BNB and another [2019] SGCA 84. It found that Shanghai, not Singapore, was the parties' chosen arbitral seat and thus PRC law was the governing law of the arbitration clause.

This ruling is an important reminder to all parties to ensure that their arbitration clauses explicitly and unambiguously specify both the arbitral seat and proper law of the arbitration clause.

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