According to Article 4/2 of the International Law on Arbitration Tribunals (“IAL”), which establishes the written condition in Turkish law, “an arbitration agreement shall be deemed to be concluded by reference to a document, including an arbitration clause, for the purpose of making that document part of the main contract”. Therefore, the inclusion of an arbitration agreement is expressly permitted by reference in Turkish law. This case is also useful in reminding all parties that, if they do not want to be bound by an arbitration clause, they must ensure that there is no arbitration clause in the agreement itself and in all other documents that are incorporated by reference to the agreement. Otherwise, the reference arbitration clause will take effect even if the other clauses of the document containing the arbitration clause are devoid of details and may not be applicable. The seller appealed to the Dubai Court of Appeal and requested that the Court of Appeal set aside the judgment of the first instance and dismiss the appeal under the parties` agreement to refer their disputes to arbitration. Alternatively, the seller requested that the court refer the case to the investigation in order to prove that the signatory had signed on behalf of the buyer disputes arising from the performance of the contract for the sale of the land and agreed to refer to arbitration Naranjillo was a Peruvian agricultural cooperative of cocoa and coffee producers and Transmar was a cocoa auction house in New Jersey. The parties concluded six substantially similar unilateral agreements concerning the supply of cocoa butter to Transmar in Germany. (The agreements differed only in shipping data, product quantities, and resulting prices.) Any unilateral agreement has been written on the transmar header entitled “Standard Contract 2-A”. The 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“NYC”), which also deals with the obligation of States Parties to recognize and enforce arbitration agreements, stipulates in Article II(3) that the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“NYC”) which also addresses the obligation of States Parties to recognize and enforce arbitration agreements, states in Article II (3) that Transmar argued that Naranjillo was nevertheless in the notification, to request the conditions to be included by reference. The court contradicted and found that “Naranjillo was not able to seek an arbitration agreement, as he was not warned that there was an arbitration agreement.” In this regard, the Court held that neither the unilateral cocoa butter contracts nor the reference in those contracts to the “Standard 2-A contract of the Cocoa Merchant Association of America, Inc.” indicated the existence of an arbitration agreement. . . .