Michael Crane QC, instructed by Clyde & Co., represented the successful insurers in an appeal by the insured against an anti-suit injunction restraining proceedings in the courts of Brazil and enforcing a London arbitration clause. The appeal raised questions regarding the proper law of a London arbitration clause contained in a contract governed by Brazilian law and containing an exclusive Brazilian jurisdiction clause. As well as reviewing English conflict of laws rules on arbitration clauses, the Court of Appeal held that a clause in the contract requiring an initial attempt to settle disputes by mediation was not a condition precedent to arbitration.