Conflict of laws

The Court of Appeal, Civil Division, held that English court had jurisdiction pursuant to s 5 of Regulation (EU) 1215/2012 to determine a dispute arising out of the claimant’s employment with an English company whose parent company was a Massachusetts company, in circumstances where the claimant’s contract of employment contained an express choice of Massachusetts law and an exclusive jurisdiction agreement in favour of the courts of Massachusetts. The court allowed the claimant’s appeal against an order dismissing his application for an anti-suit injunction on the basis that it was bound by the decision in Samengo-Turner v J & H Marsh & McLennan (Services) Ltd [2007] 2 All ER (Comm) 813.