The AAA award between the parties had established, inter alia, that Hawaiian had failed to timely pay for goods received under a license agreement, in an amount of US$ 179,000. Tanning had then lodged a proof of debt with the liquidator of Hawaiian, which had been wound up, but the liquidator had rejected Tanning’s proof of debt. The court of appeal had held the proceedings should be stayed pursuant to Section 7(2) of the International Arbitration Act 1974 and the matter referred to arbitration. The High Court dismissed Tanning’s appeal from that decision, finding that the liquidator was a person claiming “through or under” Hawaiian within the meaning of Section 7(2). It reasoned that to exclude from the scope of an international arbitration agreement binding on a company matters between the other party to that agreement and the company’s liquidator would give such agreements an uncertain operation.