In this In Depth, we analyse the Supreme Court’s highly anticipated judgment in the Kabab-Ji SAL v Kout Food Group matter. The Supreme Court has upheld the Court of Appeal’s refusal to enforce a Paris-seated award on grounds that the tribunal wrongly asserted its jurisdiction. As we set out in more detail, although the decision provides useful guidance on the process under English law for determining the law governing the arbitration agreement, it further entrenches the divide between the UK and French courts’ approaches to arbitral tribunal’s jurisdiction.