The Court of Appeal upheld the decision that Gard’s excess of loss reinsurance claim should be heard by the English court. Gard had established a choice of English law by the parties under the Rome Convention and the reinsurance was part of a London market placement. The claim against Glacier Re was intrinsically connected with the claims against the English insurer and broker and there would be a risk of irreconcilable judgments were the claim against Glacier Re to be determined by the Swiss courts (Gard Marine & Energy Ltd v Tunnicliffe