Referring to fiona Trust`s decision, Akenhead J. concluded that the question of whether a settlement had been entered into in respect of amounts due under a construction contract was a dispute arising from that subcontracting. He noted that « the courts at the highest level strongly abandon such . And that in adjudication cases, the courts should follow this direction. (b) an arbitration agreement may take the form of an arbitration clause in a contract or in the form of a separate agreement (submission agreement). « All disputes arising out of or relating to this Agreement, including all matters relating to its existence, validity or termination, shall be referred to arbitration in accordance with the LCIA Rules and shall be finally settled, which shall be presumed to be incorporated by reference to this clause. The number of arbitrators shall be [one/three].