Growing Singapore Dispute Arbitration Sector Lures Australian Barristers
The city-state, which has been working to improve its stature as a destination for international arbitration, is now the third most preferred seat of arbitration in the world and top in the Asia-Pacific, according to a 2018 international arbitration survey.
October 07, 2019 at 05:00 AM
5 minute read
A group of Australian barristers has established chambers in Singapore, in another sign of the island city-state's growing stature as a destination for international arbitration.
Known as Maxwell 42, the permanent chambers and offices are in the heart of the international arbitration centre in Singapore and include prominent barristers such as Bret Walker SC, Mark Ambrose QC, John Sheahan QC and former Federal Court of Australia judge Roger Gyles QC.
"The birth of it really was to provide an avenue for Australian barristers to have a presence in Singapore and to offer an alternative to the London bar," said Mark Johnston, a Brisbane-based barrister who is also a member of the chambers.
London chambers, including Twenty Essex and Fountain Court, also have offices in Singapore, and Johnston said they have picked up large amounts of work on disputes arising out of Australia, particularly between international and Australian parties in the resources and project sectors.
"If you're an international company and you're doing a big project in Australia and one of the other parties is a big Australian company, rightly or wrongly, there might be a perception that you'd rather be in neutral territory," he said.
"Often the contracts have an arbitration clause and the arbitrations are seated in Singapore with the application of Australian law. Once that happens, it's opened up to the field, if you like, and the London bar, in particular, has been capturing a lot of this work from Australian projects."
The barristers will operate on what Johnston describes as a fly-in, fly-out arrangement, where he, for instance, will visit Singapore perhaps half a dozen times a year.
Arbitration has become an alternative to the court system around the world as business has become more global and as more nations have signed the New York Convention, agreeing to recognise and enforce foreign arbitral awards. As of April 2018, the convention had 160 state parties.
"With the rise in cross-border commercial transactions, more cross-border differences may arise. When they do, parties need fair and efficient ways to resolve disputes in a timely manner. Singapore has developed a comprehensive suite of dispute resolution services, which includes mediation, arbitration and litigation, to support businesses in their dispute resolution needs," the Ministry of Law said in a statement.
According to the 2018 International Arbitration Survey by Queen Mary University of London and law firm White & Case, Singapore is now the third most-preferred seat of arbitration in the world, and top in Asia-Pacific. The Singapore International Arbitration Centre (SIAC) is the third most-preferred arbitral institution globally and top in Asia.
New case filings at SIAC have increased fourfold during the past decade and in 2018 SIAC handled 402 cases for parties from 65 jurisdictions.
"Singapore now stands shoulder to shoulder with historic seats such as London and Paris," SIAC said in a statement.
The rise of Singapore as an arbitration destination has been the result of a concerted effort by the government. The city-state has a stable government and a trusted and stable legal system, lawyers say. And it has an open regime where lawyers from other jurisdictions are free to act in arbitrations. In addition, they note that the Ministry of Law is quick to change laws when required to facilitate arbitrations.
The government also recently opened Maxwell Chambers, a specially designed dispute resolution complex, which provides 10 custom-designed and fully equipped hearing rooms and 12 preparation rooms and the services needed to carry out arbitrations, such as transcription and interpretation.
Singapore has become an attractive destination for western companies that might not have confidence in the legal system of the country in which the other party to a dispute is based. Likewise, some Asian parties to disputes also often want "neutral" territory for their matters.
As a small nation with no natural resources and few global-scale businesses, Singapore rarely has companies that are parties in a dispute, so is seen as neutral territory, said Smitha Menon, a partner in the international arbitration and restructuring and insolvency practice at Singapore firm WongPartnership, and chair of the International Chamber of Commerce (ICC) Singapore Arbitration Group.
"We see ourselves as a gateway between the east and west," she said.
There is a strong interest from the legal profession in making Singapore an effective arbitration centre for the region and to be the Asian equivalent of arbitration centres in London and Geneva.
"The government, arbitration practitioners like myself and the courts all sing the same tune," she said.
The ICC, the world's largest global business organisation, is responsible for the ICC International Court of Arbitration, which administers arbitrations under the ICC's rules. Since opening in Singapore two years ago, the number of cases heard there "far outstrips" many of the other ICC locations, Menon said.
Singapore is also home to several other top international arbitration institutions, including the Permanent Court of Arbitration, World Intellectual Property Organisation Arbitration and Mediation Center and the American Arbitration Association – International Centre for Dispute Resolution.
Maxwell 42's Johnston expects Singapore to continue to grow as an arbitration destination, particularly on the back of China's Belt and Road Initiative, a global development strategy to better connect China with other markets via transport and trade infrastructure.
He expects "a lot of litigation and dispute work" to come from the project and that Singapore will pick up much of the work that might have otherwise gone to Hong Kong – the other major Asian arbitration destination – because of perceptions about its neutrality.
|Related Reading:
Does Hong Kong Have What It Takes to Be Asia's Arbitration Hub?
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