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Justice Philip Jeyaretnam: Keynote Address at the 16th Annual International Conference of the Nani Palkhivala Arbitration Centre
The Impact of International Commercial Courts on International Arbitration
Keynote Address at the 16th Annual International Conference of the Nani Palkhivala Arbitration Centre
New Delhi, 6 September 2025
The Honourable Justice Philip Jeyaretnam
President, Singapore International Commercial Court
Judge of the High Court1
1 It is an honour to address this august gathering of leading arbitration practitioners. I commend the Nani Palkhivala Arbitration Centre for its efforts in strengthening arbitration both in India and globally. It is a special honour to follow in the footsteps of my Chief Justice, Sundaresh Menon, who delivered the keynote address in 2018 at the 10th edition of this conference.2 In his address, CJ Menon compared the territorial and delocalised approaches to international arbitration in the context of the role of national courts at the seat of arbitration with a focus on the question of whether parties should be bound by prior decisions of the seat court when it comes to the same issues being raised at the enforcement stage in other courts. Since that address, CJ Menon delivered judgment in the important case of The Republic of India v Deutsche Telekom AG where the Singapore Court of Appeal applied transnational issue estoppel in holding that the parties were bound by an earlier decision of the Swiss court, which was the seat court.3
2 International commercial courts anchor transnational commercial justice including international arbitration and international mediation. My address relates international commercial courts to the theme of this 16th edition of the annual conference, which is “Navigating Arbitration in the Era of Digitisation and Reform”. I will speak about both these postulated characteristics of today’s era, first “reform” and then “digitisation”. The word “reform” already suggests that there are things in the world of arbitration that must be put right or at least, can be improved. I will identify two ways in which international commercial courts may have a positive role to play in relation to the reform of both international commercial arbitration and investor-state-dispute-settlement. The first role is a direct one. It lies in the judicial support for and supervision of international arbitrations. The second role is an indirect one. It arises from providing an attractive alternative to international businesses and states. International commercial courts showcase best practices in case and hearing management. This has a salutary effect on arbitral institutions considering how to improve the quality, efficiency and speed of arbitrations administered by them.
3 The other word used in the conference theme is “digitisation”. This word refers both to the changes wrought by the past quarter century of technological change in document creation and management as well as how that change has accelerated with the advent of artificial intelligence and of AI tools. I will discuss the directions this may take in two contexts: that of complex commercial disputes and that of routine commercial disputes.
What are International Commercial Courts?
4 I start by explaining what international commercial courts are. I focus on the model pioneered by the Singapore International Commercial Court, otherwise known as the SICC, which is being adopted in the forthcoming Bahrain International Commercial Court, or BICC, that will be launched in November of this year.
5 As its name suggests, the SICC is designed to resolve high value, complex commercial disputes that because of their cross-border nature involve multiple systems of law. Parties who engage in business and trade across borders come from many different countries. They seek neutral fora, because neither party would want the other to have home-ground advantage. They may choose a neutral law to govern the contract between them but their disputes may also involve issues under other laws, for example, where questions of corporate capacity or authority arise in relation to the contracting parties. There may also be issues arising under the law of the place where, for example, the project that the parties are collaborating on is situated.
6 The SICC is a court. It is a division within the General Division of the Singapore High Court. That means it is a superior court of the Republic of Singapore. Unlike courts which principally derive their jurisdiction territorially, the SICC principally derives its jurisdiction from party choice. Singapore is a signatory to The Hague Convention on Choice of Courts. However, the SICC also has the powers of a Singapore superior court and as such it has jurisdiction to join third-parties to proceedings in appropriate cases regardless of party consent.
7 The SICC was set up to supplement, support and anchor Singapore’s then emerging role as a preferred hub for the resolution of cross-border disputes that had no connection with Singapore. By 2012, Singapore had become one of the two preferred arbitration seats in Asia, along with Hong Kong. Many international businesses were already choosing Singapore as the seat of arbitration in the event of a dispute. In that same year, Singapore hosted the 21st Congress of the International Council for Commercial Arbitration, ICCA. This was the result of a successful bid led by Chief Justice Sundaresh Menon, in his previous capacity as Deputy Chairman of the Singapore International Arbitration Centre (the “SIAC”).4 But there were some signs of unease concerning the efficiency and effectiveness of international arbitration. It was felt that a court designed to dispense transnational commercial justice could offer international businesses with an additional option: an option that might combine some of the strengths of the court system with some of the strengths of international arbitration.
8 International arbitration thrived because businesses contracting with each other across borders did not want to put their disputes into the courts of a country to which the other party belonged. Initially, three-member tribunals became widespread because each party desired to nominate one arbitrator, with the third either being chosen by the two party-nominees or by an arbitral institution. However, over time, having a three-member tribunal for larger disputes became valued for its own sake. This is because having three members enables a combination of expertise in different national laws or in different fields of law. Three minds are usually better than one, especially if they have complementary skills and experience.
9 For the same reason, three SICC judges typically sit together to hear first instance matters. This is appropriate because of three characteristics of disputes in the SICC. They are:
(a) High value and high stakes;
(b) Complex and often involving more than one specialised field of law; and
(c) Cross-border and so often involving more than one system of law.
10 As SICC is a court, parties do not choose the judges. The composition of the coram is determined by the SICC’s working committee which includes ex-officio the Chief Justice and the President of the SICC. In doing so, the working committee considers the legal specialty, commercial experience and jurisdictional qualifications of the judges. The judges appointed to the SICC and from whom any individual coram is drawn are experienced commercial judges. Uniquely, the SICC combines three pillars of judicial expertise: Singapore commercial judges, international common law judges and international civil law judges. There is great value in combining the experience and expertise of Singapore judges with international judges from leading common law and civil law jurisdictions. Cases may be heard by a coram of three made up of a Singapore commercial judge, an international common law judge and an international civil law judge. Each brings to the matter their complementary expertise and experience.
11 Zeroing in on the superintendence of international arbitrations, the combined experience and expertise of Singapore judges and international judges from leading common law and civil law jurisdictions is extremely valuable. I illustrate this point from my own personal experience.
12 In CNA v CNB and another and other matters,5 the Court at first instance considered a tribunal’s jurisdiction to decide issues arising from a purported termination of its mandate. The coram comprised a Singapore judge, an international common law judge whose speciality is intellectual property law and an international civil law judge. A co-licensor of software had commenced arbitration under the International Chamber of Commerce (the “ICC”) against the licensee. The other co-licensor which was now majority owned by the licensee executed a new arbitration agreement with the respondent licensee, submitting the same dispute to another arbitral institution. This was done purportedly on behalf of both co-licensors pursuant to an alleged general authority to act for the claimant co-licensor. So the licensee then asserted that the ICC tribunal had lost its mandate to continue with the arbitration. The tribunal disagreed and proceeded to issue its award. The aggrieved respondents applied to the SICC to set aside the award on jurisdictional grounds, ie, that the tribunal’s mandate had been terminated. The SICC upheld the award but for our purposes, what is significant is that on the question of authority and the duties of an agent, the SICC heard submissions under both Korean and Singapore law. We heard directly from the parties’ respective Korean law experts at the hearing, not as expert witnesses but as counsel. Having a civil law judge as a member of the coram facilitated our grasp of the Korean law issues.
13 Combining three judges of distinct jurisdictional expertise is not merely of practical advantage in individual cases. It is also the jurisprudential purpose of the SICC.6 The example I just cited concerned a leading example of transnational commercial law, namely the UNCITRAL Model Law on International Commercial Arbitration. There are an increasing number of such model laws that benefit from a combined civil and common law exegesis, for example in the field of cross-border insolvency and electronic commerce.
Direct Role: Judicial Support for and Supervision of International Arbitrations
14 Let me now turn to the role that international courts, like the SICC, play in relation to support for and control of international arbitrations.
15 On the aspect of support for arbitrations, the SICC is empowered by s 12A of our International Arbitration Act 1994 (the “IAA”) to grant interim relief in support of international arbitrations that are seated in Singapore or even outside Singapore. There is a general condition that the SICC can only do so where the tribunal has no power to grant the interim relief sought or is unable for the time being to act effectively, such as where the tribunal has not yet been constituted.7 Where the seat of the arbitration is outside Singapore, then the court must consider whether that fact makes it inappropriate to grant the order sought.8 I recently granted a worldwide freezing order (which is also known as a Mareva injunction) in relation to a New York seated arbitration and subsequently dismissed the application to set it aside.9 The defendants were a Singapore company and a Singapore citizen. An interesting point that arose was whether it was appropriate to grant such relief given that it is apparently not available under New York law. It was contended that granting Mareva relief would “cut across the grain of parties’ chosen curial law”.10 However, I ultimately found that it was not inappropriate to do so as the evidence showed that the grant of Mareva relief is not considered to be objectionable by New York courts, which have in fact enforced Mareva injunctions granted by foreign courts.11 I should add that my decision is under appeal.
16 Nonetheless, this case exemplifies how the SICC supports arbitration as an international commercial court even though the arbitration is seated outside Singapore. The SICC thus plays a role in relation to transnational commercial justice generally.
17 On the aspect of supervision of arbitration, the SICC often deals with questions of jurisdiction of arbitral tribunals. In determining such questions, it is frequently necessary to interpret the arbitration agreement. It is a modern truism that courts facilitate and protect party autonomy by striving to make arbitration agreements workable and effective. As Gary Born has written: “… courts from virtually all jurisdictions have displayed a pronounced willingness to disregard or minimize imperfections in the parties’ arbitration agreement, to imply missing terms and/or to adopt liberal interpretations in order to supply omitted terms or to reconcile apparently inconsistent terms”.12 The principle of effective interpretation certainly marks a sea change from the days of yore when the paradigm and default mode of dispute resolution was thought to be the courts and so any drafting flaw would more likely have been resolved in the opposite direction, ie, against there being an effective reference to arbitration.
18 Thus, the language of an arbitration clause must now be considered in the light of the parties’ manifested intention that their disputes relating to the contract are to be determined in arbitration, rather than by a court. Someone who has an intention to do X would not typically mean to say something that would thwart that intention.
19 Let me illustrate this with two decisions. The first is one of my own decisions, Re Shanghai Xinan Screenwall Building & Decoration Co, Ltd.13 There, I dismissed an application to set aside the registration of an award. One of the arguments raised by the applicant was that the parties had agreed that the dispute be referred to a non-existent arbitral institution, namely, the “China International Arbitration Center”. As it happened, the respondent submitted the dispute to the China International Economic and Trade Arbitration Commission (“CIETAC”). CIETAC had accepted the arbitral reference and administered the parties’ dispute. The applicant did not participate in the arbitration, asserting that it had not been properly notified of it, a separate ground of challenge which did not succeed on the facts. My task was to construe the arbitration agreement between the parties to determine whether CIETAC was right to conclude that it was the selected arbitral institution. I put the point like this in my opening paragraph:
When I bump into my childhood friend Ben and call him Bill, I am not inventing an imaginary friend, but simply mistaking his name. In the same way, when the name of the arbitral institution in an arbitration agreement does not precisely correspond with that of any existing arbitral institution, it is not that parties have chosen a non-existent institution. Rather, the question is whether they intended the same institution, whether they had in mind different ones or whether it is impossible to tell either way. Only in the latter two cases does the misnomer affect the validity of the arbitration agreement.
20 Another matter where effective interpretation came into play was the Court of Appeal decision of Anupam Mittal v Westbridge Ventures II Investment Holdings.14 The question was whether a shareholders’ dispute relating to an Indian company was arbitrable. Under the shareholders’ agreement (“SHA”), the governing law was Indian law, and all disputes arising between the parties that could not be resolved by good faith discussion were to be referred to arbitration seated in Singapore. At this point, I should mention that the arbitration clause specifically included disputes “relating to the management of the Company”.15
21 The laws of India and Singapore differ when it comes to the types of company disputes that are arbitrable. In Singapore, unlike in India, allegations of minority oppression under the Companies Act are arbitrable.16 Consequently, the court had to decide whether the proper law of the arbitration agreement was Indian law or Singapore law.
22 In 2017, Westbridge expressed its wish to exit the company. The parties’ relationship had soured. In 2021, Mittal commenced proceedings before the National Company Law Tribunal (“NCLT”) in Mumbai, India, seeking remedies for corporate oppression (“NCLT Proceedings”).
23 In response, Westbridge commenced proceedings in Singapore and obtained an ex parte interim anti-suit injunction against Mittal. Mittal submitted that arbitrability is determined by the law of the arbitration agreement, and that this was Indian law. The disputes raised in the NCLT Proceedings related to oppression and the mismanagement of the company.
24 The first issue dealt with by the Court of Appeal was which law governs the issue of arbitrability –the law of the seat or the law of the arbitration agreement. The authority of an arbitration agreement derives from parties’ consensus. Accordingly, the Court of Appeal held that subject matter arbitrability is determined first by reference to the law of the arbitration agreement. Logically, the making of a valid arbitration agreement precedes the choice of seat. The seat is chosen as one of the incidents of the arbitration agreement. If the arbitration agreement is not valid, then there would be no effective choice of seat. For an arbitration to proceed in Singapore, it must be arbitrable both under the law of the arbitration agreement and under the law of Singapore, as the law of the seat – a doctrine of “double arbitrability” if you will.
25 Turning to the proper law of the agreement, the Court of Appeal applied the three-stage test, previously laid out in BCY v BCZ [2017] 3 SLR 357 following the English case of Sulamerica Cia Nacional da Seguros SA v Enesa Engelharia SA [2013] 1 WLR 102. At the first stage, the court considers whether there was an express choice of the law governing the arbitration agreement. At the second stage, if there was no express choice, the court then considers whether there was an implied choice. At the third stage, if there was no express or implied choice of governing law, the court considers which law has the most real and substantial connection with the arbitration agreement.
26 Having held that there was no express choice, the Court of Appeal turned to implied choice of law to govern the arbitration agreement. This ordinarily follows the express choice of the law governing the contract unless there are circumstances negating that conclusion. Here, the law governing the SHA was Indian law. However, the usual inference to be drawn from this was negated by the fact that applying Indian law would have frustrated the parties’ intention to arbitrate all their disputes. The parties had clearly spelt out their desire to arbitrate disputes relating to management of the company. It was a commercial agreement for which the parties had plainly given considerable thought. It would not make sense for the parties to impliedly choose a law to govern their arbitration agreement that would not enable their intention to arbitrate to be fulfilled. The Court of Appeal hence moved to the third stage of the inquiry and found that Singapore law had the most real and substantial connection with the arbitration agreement, given that Singapore had been expressly chosen as the seat. Thus, the proper law of the arbitration agreement was Singapore law.
27 Consequently, the Court of Appeal dismissed the appeal and upheld the grant of the permanent anti-suit injunction. Parties were unlikely to have impliedly chosen Indian law to govern the arbitration agreement given that such a choice would thwart their express intention to arbitrate disputes relating to management of the company.
Indirect Role: International Commercial Courts’ salutary effect on arbitral institutions
28 Having canvassed the direct role that international courts play in supporting and controlling international arbitrations, I now turn to the second and indirect role that international courts like the SICC have on international arbitration simply by offering an attractive alternative. There are procedural features of an international commercial court that may be more appropriate and effective for some types of cross-border dispute. These include the ready ability to join third parties to proceedings and the potential availability of appeals enabling errors to be corrected. However, my focus is on the salutary effects exerted by the existence of an alternative mode of resolution, namely on quality, efficiency and speed.
29 A key feature of the rule of law is that the law is applied fairly and consistently, what Lon Fuller described as “congruence” between the law as publicly announced and as administered.17 Judges are accountable for the congruence of their decisions through their reasoned judgments that are published and open to scrutiny not just by parties, but by lawyers and the world at large. Transparency and accountability are critical mechanisms that operate to ensure the quality of decision-making in a court system. Over the 10 years since its’ launch, the SICC has issued more than 180 judgments at first instance and close to 50 at the appellate level, demonstrating the quality of justice.
30 Turning to efficiency, the SICC applies case and hearing management procedures and techniques that while customised for each dispute, also draw on a panoply of options. Case management is judge-led and occurs from an early stage of proceedings, with regular case management conferences.
31 In terms of speed, final hearing dates are fixed at an early stage with interlocutory applications streamlined to meet those dates. Even complex cases can be heard and disposed of within a year to 15 months. A recent matter involving complex technical expert evidence which was filed in the SICC in November 2024 is scheduled for ten days of hearing within one year, namely in November 2025.
Reform of Arbitration
32 All the salutary features of international commercial courts that I have described offer or suggest potential ways for reform of international arbitration to improve its quality, efficiency and speed, especially in complex cases. While I commend the efforts undertaken to address some of these concerns, I will proceed to highlight areas where further reform may be beneficial.
33 I begin with quality. Because of the confidential nature of arbitration, awards are only given to the parties. While they contain reasons, these reasons are provided only for the benefit of the parties, and to a limited extent, for a court reviewing a challenge to the award, which essentially would be limited to review on jurisdictional and due process grounds. This has three drawbacks:
(a) Commercial law is not developed;
(b) Arbitrators’ legal reasoning is not scrutinised by academics or the profession generally; and
(c) Public interest or third-party concerns are left unaddressed. For example, investor-state arbitration disputes between businesses and states that may implicate matters of public concern such as the environment and public health are largely shielded from public view and debate.
34 I mention three ways to improve quality. One has been for institutions to encourage the publication of awards, whether in full or redacted anonymised form. However, there is a considerable time lag in such publication and it requires consent from all parties. Such consent is often not forthcoming.
35 A second has been to identify the members of arbitral tribunals in their judgments in the belief that greater transparency and accountability fosters quality. This underpins the practice of the Singapore Courts which for some years now has identified arbitrators. Confidentiality in arbitrations is for the benefit of the parties not for the protection of arbitrators from public scrutiny.
36 A third is to introduce avenues of appeal from arbitral awards to international commercial courts, both for error correction and for the sustained development of legal principles in the field of transnational commercial law.
37 Turning to efficiency, it is often said that the phenomenon labelled “due process paranoia” inhibits efficiency in arbitration. This is the fear, whether justified or not, of a successful challenge to an award on due process grounds. This is said to have caused arbitrators to adopt a defensive and timid approach to case management. The result is that parties are given overly long timelines and arbitration proceeds at the pace of the slowest participant. William Rowley KC has pointed to arbitrators being “just too scared to implement robust procedural requirements because counsel have complained that they are not being given a full opportunity to present their case, which always raises the temperature in the arbitration room”.18
38 Counteracting this “due process paranoia” would require arbitral institutions to tweak their rules to signal greater empowerment of arbitrators as well as strengthening training and education for arbitrators. The approach reflected in the jurisprudence of the SICC is that the court should only intervene if the tribunal did something in its conduct of proceedings that falls outside the range of what a reasonable and fair-minded tribunal in those circumstances might have done.19 This entails the court considering the circumstances at the time of the decision, including the conduct of parties, and gives tribunals a broad discretion to manage proceedings.
39 In part because of the failure to manage arbitration proceedings effectively, the time taken for complex arbitrations has continued to increase, and the speed of arbitration in complex cases is far slower than what a commercial court like the SICC achieves.
Digitisation
40 Dispute resolution is a field in which technology – and specifically the use of digital and algorithmic technology, including AI – promises to help manage cases, reduce delays and ease the burden of voluminous documentary and other evidence on the decision-maker.
41 It is commendable that arbitral institutions have adopted online case management platforms, which streamline and secure communication and document-sharing in arbitral proceedings.20 One such platform is the new online case management platform by the SIAC, known as the SIAC Gateway which is referred to in the SIAC Rules 2025.21 In time, these online case management platforms may themselves evolve to incorporate AI-powered capabilities to assist arbitrators, lawyers and parties alike. In the judicial context, such a platform is being developed by the Singapore Judiciary in collaboration with Harvey AI, starting with a platform for self-represented persons at the Small Claims Tribunals. This platform offers tools to help self-represented persons file their claims, understand what evidence they need to produce, organise their materials, present their cases and so on.22
42 When it comes to complex cases, AI too holds great promise as a way to help decision-makers, whether judges or arbitrators, navigate in a more accurate and cost-efficient manner the ever-growing volume of evidentiary material. For example, AI tools could be used to detect conflicting statements or essential patterns within the evidence.23 Indeed, when used responsibly, AI can also be used at source by counsel to make their submissions more digestible, so long as counsel keep in mind that they remain fully accountable for what they submit.
43 Yet, our optimism must be accompanied by an appreciation of the risks. It is telling that the first omnibus legislation regulating AI in the world, the EU AI Act, classifies the use of AI systems by alternative dispute resolution bodies for the administration of justice as high risk.24 The potential risks are illustrated by a current case in the US Federal Court, LaPaglia v Valve Corp. In this case the claimant has filed an application to vacate an arbitral award on the ground that the arbitrator had relied on AI in drafting critical sections of the award to the extent that he had outsourced his adjudicative role. Without due care, the introduction of AI into arbitration – through intended to improve it – may inadvertently diminish transparency and accountability.
Conclusion
44 International commercial courts such as the SICC have a critical role to play in providing a supportive, facilitative and ultimately nurturing role in the emerging system of transnational justice. International commercial courts strengthen access to justice and the rule of law by offering users a choice of dispute resolution that is appropriate and responsive to their needs and preferences, and it is this quality that makes international commercial courts critical contributors to the transnational system of commercial justice.25
45 At the SICC Conference held in January to commemorate the SICC’s 10th anniversary, Senior Minister Lee Hsien Loong observed that domestically, the strong rule of law has been a cornerstone of the Singapore model and has underpinned our progress as a nation.26 In a troubled geopolitical environment, he observed that the international rule of law becomes all the more important and precious because countries still need to co-exist and work with one another.
46 It is in this context that a new chapter has opened in Singapore’s story of support for transnational commercial justice.27 This year, we launch the International Committee of the SICC (the “International Committee”), which will hear prescribed civil appeals from international commercial courts situated outside of Singapore. This arises initially from our collaboration with the Kingdom of Bahrain in relation to the establishment of its new international commercial court, the Bahrain International Commercial Court (“BICC”). The BICC is modelled principally on the SICC. There is provision for appeals from the BICC to the International Committee pursuant to a bilateral treaty between our respective nations. Linking international commercial courts across different jurisdictions strengthens the anchoring role that they play in complementing non-court-based modes of dispute resolution such as arbitration and mediation. Indeed, such links uphold and promote the international rules-based order.
47 The effective and efficient adjudication of cross-border commercial disputes takes place against the backdrop of the international rules-based order. Today’s exchange of ideas furthers the pursuit of this vision. I thank you for your attention and look forward to engaging in a meaningful discussion on these important issues.
(1) I gratefully acknowledge the assistance of JLC Kit Pang in the preparation of this Keynote Address.
(2) Keynote address by Chief Justice Sundaresh Menon at the 10th Annual International Conference of the Nani Palkhivala Arbitration Centre, The Role of the National Courts of the Seat in International Arbitration (17 February 2018) (https://www.judiciary.gov.sg/docs/default-source/news-docs/chief-justice_keynote-address-delivered-at-the-10th-annual-international-conference-of-the-seat-in-international-arbitration.pdf) (accessed 14 August 2025)
(3) [2024] 1 SLR 56.
(4) Annex to Second Reading Speech by Minister for Law K Shanmugam on the International Arbitration (Amendment) Bill (9 April 2012), Ministry of Law Singapore <https://www.mlaw.gov.sg/files/news/parliamentary-speeches/2012/04/linkclick7460.pdf> at paragraph 19 (accessed 14 August 2025).
(5) [2023] 5 SLR 1.
(6) Opinion editorial by Justice Philip Jeyaretnam, Singapore’s new chapter in the story of transnational commercial justice (15 November 2024), The Business Times Singapore <https://www.businesstimes.com.sg/opinion-features/singapores-new-chapter-story-transnational-commercial-justice> (accessed 15 August 2025).
(7) IAA at s 12A(6).
(8) IAA at s 12A(3).
(9) Novo Nordisk A/S v KBP Biosciences Pte Ltd and another [2025] SGHC(I) 22.
(10) Ibid at [104].
(11) Ibid at [107].
(12) Gary Born, International Commercial Arbitration (Kluwer Law International, 2nd Ed, 2014), at pp 775–776.
(13) [2022] 5 SLR 393.
(14) [2023] 1 SLR 349.
(15) Ibid at [6].
(16) Ibid at [75].
(17) Lon L Fuller, The Morality of Law (Yale University Press, 2nd Ed, 1969), at p 39.
(18) News article by Alison Ross, "Too many faces in the trough": why the roundtable was needed (23 July 2024), Global Arbitration Review <https://globalarbitrationreview.com/article/too-many-faces-in-the-trough-why-the-roundtable-was-needed> (accessed 15 August 2025).
(19) China Machine New Energy Corporation v Jaguar Energy Guatemala LLC and another [2020] SGCA 12 at [104].
(20) Magdalena Łągiewska, New Technologies in International Arbitration: A Game-Changer in Dispute Resolution? (13 December 2023), International Journal for the Semiotics of Law, at pp 855–856.
(21) Arbitration Rules of the Singapore International Arbitration Centre (7th Ed, 1 January 2025).
(22) Chief Justice Sundaresh Menon, Keynote Speech at the Small Claims Tribunals 40th Anniversary Symposium, The Small Claims Tribunals and the Delivery of Justice: The Past, Present and Future (16 April 2025), at paragraph 18.
(23) CIArb Guideline on the Use of AI in Arbitration (2025), at paragraph 1.3.
(24) EU AI Act at Recital 61, Annex III.
(25) Speech by Chief Justice Sundaresh Menon at the 7th International Bar Association Asia Pacific Regional Forum Biennial Conference, Dispute Resolution at the Intersection of Domestic and Transnational Justice Systems: The Case for International Commercial Courts (23 February 2023), at paragraph 4.
(26) Speech by Senior Minister Lee Hsien Loong at the Singapore International Commercial Court Conference 2025 (14 January 2025) <https://www.pmo.gov.sg/Newsroom/SM-Lee-at-Singapore-International-Commercial-Court-Conference-2025> (accessed 15 August 2025), at paragraphs 5 and 17.
(27) Opinion editorial by Justice Philip Jeyaretnam, Singapore’s new chapter in the story of transnational commercial justice (15 November 2024), The Business Times Singapore <https://www.businesstimes.com.sg/opinion-features/singapores-new-chapter-story-transnational-commercial-justice> (accessed 15 August 2025).
2025/09/10
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