CHAPTER 33 - Singapore - Interim Measures in International Arbitration
Colin Y. C. Ong
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Originally from: Interim Measures in International Arbitration
Singapore has two separate arbitral systems that operate in parallel.
International arbitrations are governed by the International Arbitration
Act (Cap. 143A) (“IAA”) which has been amended several times in
2004, 2010, and 2012. The IAA gives force of law to the UNCITRAL
Model Law on International Commercial Arbitration in respect of
international arbitrations. The other arbitral system is for domestic
arbitration and is governed by the Arbitration Act (Cap. 10) (“AA”).
Singapore was one of the earliest jurisdictions in the Asia-Pacific
region to have incorporated the 1985 Model Law into its legislation and
is widely acknowledged as an established leading UNCITRAL Model
Law jurisdiction. Article 5, one of the most important features of the
Model Law, prevents the national courts from intervening in an
arbitration unless there is an express provision in the Model Law to the
contrary. Article 17 of the Model Law gives arbitral tribunals seated in
Singapore rather wide powers to grant interim measures of protection
sought by an applicant. Article 9 of the Model law allows for judicial
assistance with regard to the granting of interim measures to support an
RELIEF PROVIDED BY COURTS
1. (a) Are courts authorized to issue orders of attachment,
injunctions or other provisional orders with respect to
(b) If so, please describe the nature of any such provisional
relief that is available.
2. What are the conditions that must be satisfied by an applicant for
a court to grant provisional remedies in relation to arbitration?