Abstract

In August 2015, the Singapore International Arbitration Centre announced that the process of revising its 2013 arbitration rules had begun. This process was commenced with a view to the release of a revised version of SIAC's arbitration rules in mid-2016. Upon this announcement, SIAC commenced the process of consultation for which this submission was prepared.This submission addresses one particular aspect of the SIAC Rules 2013 - the way in which arbitrators identify the substantive law governing the merits of the parties' dispute, where the parties have not themselves made a choice of law. It argues that the Revised SIAC Rules should depart from the position currently taken in Art. 27(1) SIAC Rules 2013 by adopting the closest connection test (rather than the voie directe), and by allowing arbitrators to apply rules of law (rather than only law).

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