Abstract
Hong Kong, Australia and India represent three different tiers in a posited hierarchy of arbitral seats. This article compares these three territories with the aim of illustrating how differences in history, law and practice inform the desirability of a location as a seat for international commercial arbitrations. Part I outlines the historical development of arbitration in each territory, finding that strong governmental and judicial support is essential to success as an arbitral seat. Part II then analyses four key areas of difference in arbitral law and practice between the comparative territories, arguing that Hong Kong is superior to Australia and India in three of these four areas. The article concludes by recalling that Asia’s increasing arbitral activity presents both opportunities and challenges for each of the territories, and the region more generally.
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