An Indian corporation and an American corporation enter a contract. The contract’s choice of law clause states: “This contract shall be governed by the laws of the state of New York.” The contract contains an arbitration clause with New York as the arbitral seat.
The parties end up in a lawsuit. The Indian company alleges a series of tort and contract claims, including tort claims that are only available under Indian law. Are these noncontract claims subject to Indian law or to New York law? Is Indian law relevant at all?
