Facts: There was a contract of marine insurance between a Kuwait-based insurer and a shipowner resident in Dubai. The contract adopted the wording of the statutory form of marine insurance policy set out in the Marine Insurance Act 1906 (UK).
Held (House of Lords): English law was the proper law of the contract, as there was no marine insurance law in Kuwait and the understanding of this marine insurance policy had to have reference to English law. Therefore, it must have been the intention of the parties that English law be the proper law of the contract.