English Commercial Court decision on inter-related issues of governing law and jurisdiction: Permission to serve English proceedings out of the jurisdiction on a Russian Defendant had been correctly granted to a Cayman Claimant, and the proceedings should continue in the English Courts. That was because: applying the Rome Convention, there was a “good arguable case” that English law governed the contract of • guarantee between them - so a “jurisdiction gateway” was established under the English Civil Procedure Rules; and England was the most appropriate forum (“• forum conveniens”) for the dispute.

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