Part III Where to Arbitrate? Distinctive Features of Maritime Arbitral Seats, 12 Common Types of Shipping Arbitration: In Singapore and London

Abstract

This chapter reflects on developments in maritime arbitration in Singapore, highlighting its distinctive features via a comparison with London, the shipping world’s preferred arbitration centre. In Singapore, the Arbitration Act (Cap 10, 2002 Rev Ed) governs domestic arbitration whereas the International Arbitration Act (Cap 143A, 2002 Rev Ed) (the ‘IAA’) governs international arbitration. The IAA gives the force of law to the UNCITRAL Model Law 1985 and the New York Convention on the Reciprocal Recognition and Enforcement of Foreign Arbitral Awards. Singapore offers the possibility to arbitrate under the institutional rules of either the Singapore Chamber of Maritime Arbitration (SCMA) or the Singapore International Arbitration Centre (SIAC). The SIAC provides institutional services, including the appointment of arbitrators. The SCMA was in recent years taken outside the structure of the SIAC to provide a service more comparable to that provided by the London Maritime Arbitrators Association (LMAA).