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

arbitration.