Easybiz Investments v Sinograin Chinatex [2010] EWHC 2656 related to arbitration proceedings commenced in relation to ten bills of lading. The Appellant Owners had entered into a voyage charterparty, under which the bills of lading were issued. The bills incorporated the terms of the charterparty, which contained a clause requiring arbitration in London under the terms of the Arbitration Act 1996 (the “Act”).

When the vessel lost its rudder and had to be towed to Cape Town for repairs, Owners declared the voyage frustrated and required Cargo Owners to take delivery of the goods in Cape Town. A cargo recovery agent subsequently purported to commence arbitration against the Appellants under all ten bills of lading. The notice of arbitration identified the parties and the bills of lading, and also provided that Cargo Owners had appointed an arbitrator “in respect of all disputes arising under the aforesaid bills of lading…”.

The arbitrator ruled on his own jurisdiction, and the Appellant appealed against this ruling under s.67 of the Act. The Commercial Court dismissed the application, holding that the notice of arbitration was valid under s.14(4) as it did not seek to initiate a single consolidated arbitration of all the claims, rather the notice was to be construed broadly as validly initiating ten separate arbitrations.