The liberal approach to construction of arbitration clauses does not create a legal presumption of arbitrability. An arbitration clause referring to 'any breach of the provisions under this agreement' is limited to disputes concerning breaches of provisions of that agreement, and does not extend to disputes concerning breaches of all contracts entered into under the umbrella of that agreement, even where the agreement is characterised as a constituent or umbrella agreement establishing a broader commercial relationship.
The full text is available to signed-in members, including the 11 later cases that cite this judgment.
2 of the 11 citing cases carry a classified treatment. How each court treated it is available to signed-in members.