How does the choice of governing law affect what happens when commercial contracts are disrupted?
Against a backdrop of geopolitical uncertainty, sanctions, tariffs and disrupted supply chains, the question of how risk is allocated between contracting parties is becoming increasingly significant.
Our member Martin Khoshdel has co-authored a new article with Catherine Hammerson-Jones of Lewis Silkin, exploring force majeure, frustration and hardship across England & Wales, the DIFC, ADGM and the UAE.
Drawing on recent developments and case law, the article considers how significantly the relief available to parties can differ between jurisdictions and why careful consideration of governing law and contractual risk allocation is so important in cross-border disputes.
Martin specialises in commercial disputes, litigation and arbitration across England & Wales, the Middle East, Caribbean and Asia, with particular expertise in jurisdictional and choice of law issues. Based in the UAE since 2021, he brings extensive regional experience across DIFC, ADGM and UAE law alongside his English law practice.
Read the full article here: https://www.lewissilkin.com/insights/2026/09/07/force-majeure-frustration-and-hardship-the-importance-of-choice-of-law-and-risk-102o0bg
