England right place for decision
LAWYERS at Herbert Smith report that in Stonebridge Underwriting Ltd v Ontario Municipal Insurance Exchange [2010], the English Commercial Court held a contract of reinsurance entered into between an Ontario insurer and a Lloyd’s syndicate was subject to English law, on the basis that the reinsurance was subject to an implied agreement in that respect – having been placed by a London broker with a London reinsurer and incorporating a number of London market standard clauses.