• those DAP Third Party Sales Contracts were between ECTG and the Indian purchasers, and Dreymoor was not a party. It was therefore never intended that any claims against Dreymoor should be subject to the ICC arbitration clause. The English High Court's conclusions The English High Court did not accept Dreymoor’s arguments, and dismissed its challenges to both arbitrations. The overall approach of the Court was commercially focussed, with the intentions of “reasonable business people” emphasised in His Honour Justice Butcher’s reasoning when faced with such a complex – and inconsistent – web of contracts:1 “The issue is one of construction of the relevant agreements, and… in considering that issue it is relevant to consider what the parties, as reasonable business people, must be taken to have intended as to how and where disputes which might arise between them should be resolved.” LCIA arbitration The Court first considered the ambit of the dispute resolution clauses in the DAP/MAP and Urea Sales Contracts (items (3) and (5)), looking at those Contracts in isolation. Applying a liberal interpretation approach, avoiding narrow distinctions, as per the House of Lords in Fiona Trust,2 the Judge concluded that the bribery disputes were covered by the Sales Contracts and their LCIA arbitration clauses. The clause which referred “any dispute or claim arising out of this contract” to LCIA arbitration, was wide enough to cover disputes which relate to non-contractual claims, including pre-contractual misrepresentation and antecedent bribery inducing the contract.3 The Court did accept that there could be circumstances in which an arbitration clause will not extend to tortious or other non-contractual claims if the parties would, at the time of conclusion of their contract, have considered that any possible contractual claim in the relevant area would have been “outlandish or unarguable”. Butcher J went on to consider the effect of the umbrella Agency Agreements (items (1) and (4)), ultimately deciding that they did not alter the conclusion that the disputes were covered by the DAP/MAP and Urea Sales Contracts. The Court noted that the absence of a jurisdiction or arbitration clause in the DAP/MAP Agency