Company E, an assured from Australia, signed a marine insurance policy with Company F, which is an insurer from Singapore. The policy covered marine and cargo risks that was related to the vessel of Company E, The Middle Hope. The policy closely followed the wordings of Lloyd’s Standard Marine Policy, but there is no express choice of law in the policy. The policy was written in English. The policy was signed in the office of Company E in Australia. The premium was paid in Singapore. There is a clause in the policy stating that “Any dispute arising out of or in connection with this policy, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration under the London Court of International Arbitration Rules, which Rules are deemed to be incorporated by reference into this clause.” Appraise the situation and decide what should be the governing law of the marine insurance policy.

Company E, an assured from Australia, signed a marine insurance policy with Company F, which is an insurer from Singapore. The policy covered marine and cargo risks that was related to the vessel of Company E, The Middle Hope. The policy closely followed the wordings of Lloyd’s Standard Marine Policy, but there is no express choice of law in the policy. The policy was written in English. The policy was signed in the office of Company E in Australia. The premium was paid in Singapore. There is a clause in the policy stating that “Any dispute arising out of or in connection with this policy, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration under the London Court of International Arbitration Rules, which Rules are deemed to be incorporated by reference into this clause.” Appraise the situation and decide what should be the governing law of the marine insurance policy.