ISSUE:
Whether clause 16 of the Deed of Partnership is a valid 'arbitration agreement'?
RULE:
Arbitration agreement must disclose a determination through words used in the agreement and obligation on behalf of parties to refer disputes to arbitration.
Where there is merely a possibility of the parties agreeing to arbitration in the future, in contrast to an obligation to refer disputes to arbitration, there is no valid and binding arbitration agreement.