This paper seeks to review the Court of Appeal's decision in O.A.U. -v- Inaolaji Builders Limited (2020) 4 NWLR (Pt. 1714) 347 and to encourage parties in an agreement to always ensure that they include the name of an arbitral institution as the appointing authority in the dispute resolution clause of their contracts, as against leaving the issue of the appointment of an arbitrator to the Court.