SIAC innovation and court decisions reinforce Singapore’s position as a leading arbitral seat

Recent developments, including new SIAC initiatives, expanded investor‑state dispute settlement (ISDS) infrastructure, and the pro-arbitration approach of its judiciary, underscore the jurisdiction’s dynamic and future‑focused arbitration landscape.

• Read more: international arbitration developments and trends for 2025-26

The Singapore International Arbitration Centre’s (SIAC) 2025 Rules came into effect on 1 January 2025, following a comprehensive review and consultation throughout 2024. The new rules - which are the second most used set of rules worldwide after the ICC rules according to the latest Queen Mary Survey - enhance efficiency in arbitration proceedings, transparency and certainty in the timeframe for issuing awards.

The latest SIAC statistics revealed a steady caseload and a wider international scope of disputes. 91% of the centre’s 625 new cases were international, with 72 jurisdictions involved, up from 66 the previous year. This increase reflected the geographical diversity of arbitrators’ appointments, with 43 jurisdictions represented compared to 38 jurisdictions in the previous year.
The total sum in dispute reached US$11.86 billion with the SIAC issuing 167 awards throughout various sectors such as trade, commercial, construction, maritime and corporate.

SIAC launched a first-of-its-kind protocol, adapting and streamlining its rules for disputes arising in the context of insolvency proceedings. The Restructuring and Insolvency Arbitration Protocol, developed in consultation with local and international judges, insolvency and arbitration practitioners and the SIAC Court of Arbitration, reflects Singapore’s position as a seat capable of handling complex cross-border dispute resolution. The protocol offers a version of the SIAC Rules 2025 specifically adapted to disputes arising in the context of restructuring, debt adjustment and insolvency.

With a similar goal of assisting arbitration users in complex arbitration proceedings, the Society of Construction Law in Singapore has issued a protocol on joint expert reports to be used in Singapore-seated international or domestic arbitrations. This framework will help experts clarify and agree on key issues while also resolving their differences efficiently, thereby supporting the resolution process.

Beyond commercial arbitration, Singapore’s role in public international law and investment arbitration continued to expand in 2025 with the opening of a new International Centre for the Settlement of Investment Disputes (ICSID) office in Singapore. This reflects growing regional demand for investor‑state dispute settlement services, supported by ICSID case data that highlights the scale of disputes globally. Furthermore, the Permanent Court of Arbitration (PCA) doubled its office space in 2025, reaffirming the PCA’s presence in the region. Pinsent Masons’ experts commented that these developments “reflect the city state’s growing role as a hub for international dispute resolution”.

The expansion of Singapore’s relationship with other jurisdictions and countries was a strong theme throughout 2025. Bahrain, Brazil, Costa Rica, Israel and Paraguay all signed the Singapore Convention on Mediation in 2025, while concentrated efforts to develop the relationship between Singapore and the Middle East and North Africa region resulted in a rise of parties engaging with the SIAC.

Continuing with innovation and evolution, Singapore opened consultation on its International Arbitration Act on its 30^th anniversary to ensure Singapore remains “remains attractive as an arbitration forum”.

Across several decisions in 2025 and the beginning of this year, the Singapore courts have consistently demonstrated minimal intervention and discouraged unmeritorious challenges.

In DMZ v DNA, the Singapore High Court ruled that it did not have jurisdiction to review a decision from the SIAC Registrar regarding the date of the commencement of the arbitration proceedings – a decision which negatively impacted the defendant’s statute of limitation defence. The Court of Appeal recently confirmed the decision of the lower court, holding that there was no room for the court to intervene in a procedural ruling made pursuant to the SIAC rules that the parties had agreed to.

In DRO v DRP, the High Court rejected a jurisdictional challenge to an award on the ground that the pre-arbitration steps had not been complied with. The court confirmed that the question of compliance with pre-arbitration steps goes to the admissibility of the claim, not to the tribunal’s jurisdiction. This is a welcome clarification as until now it was uncertain under Singapore law whether failure to comply with a pre-arbitration step could deprive a tribunal of jurisdiction. This decision also brings Singapore in line with recent decisions in the UK and Hong Kong.

In DEM v DEL, the court clarified that failure to formally serve a notice of arbitration does not invalidate an award if the respondent had actual or deemed notice and an opportunity to participate. The Court emphasized that “notice” is not the same as “service”, what matters is whether the party was aware of the proceedings and could reasonably respond.

In DLS v DLT, a litigant attempted multiple rounds of challenges to the arbitrator’s independence: before the ICC, twice before the Singapore courts, and even in foreign proceedings. The High Court applied issue estoppel to dismiss the repeated application, reaffirmed the sanctity of the seat, and imposed indemnity costs on the challenger.

In DNZ v DOB, the Singapore court recently upheld a SIAC award against Poland regarding an Energy Charter Treaty (ECT) dispute. The Singapore court dismissed Poland’s challenge and made it clear that the ECT operates as an international agreement, rather than an intra-EU bilateral investment treaty under EU law. This is an important decision because many EU member states have attempted to resist enforcement of ECT arbitration awards, raising that such enforcement is in violation of EU law. It shows Singapore courts’ pro-arbitration stance also in the context of investment arbitration.

Although adopting a minimal intervention approach, Singapore courts will not hesitate to intervene to safeguard the integrity of the arbitral process.

In India Glycols v Texan Minerals, the court partly set aside an award after finding that the tribunal exceeded the scope of submissions by holding non-signatory parties - here, ICI and a director - liable for breaches that were never pleaded or raised in the arbitration. Importantly, the court applied a two-stage test to determine scope and chose to set aside only the offending portion of the award, underscoring its commitment to minimal intervention.

In Wan Sern Metal Industries v Hua Tian Engineering, the Court of Appeal set aside part of an award rendered under SIAC’s expedited, documents-only procedure because the arbitrator had based damages on a counterclaim introduced late in written submissions, not in pleadings. The decision highlights the need for precision in pleadings in documents-only arbitrations and signals that late submissions may amount to abuse of process.

In Vietnam Oil and Gas Group v Joint Stock Company (Power Machines-ZTL, LMZ, Electrosila), the Singapore Court of Appeal set aside an award for breach of the fair hearing rule after finding that the tribunal adopted a pivotal chain of reasoning without giving parties an opportunity to address this approach. The Court emphasized that such reasoning could not have been reasonably anticipated and that remission was inappropriate due to concerns of prejudgment, underscoring the courts’ commitment to preserving the integrity of the arbitral process.

In DJO v DJP and DOI v DOJ, the courts set aside ICC awards for apparent bias and breach of natural justice after discovering that the tribunal had substantially “cut and pasted” from prior Indian-seated awards and introduced authorities not raised by the parties. These decisions highlight that while Singapore courts rarely intervene, they will not hesitate to do so where procedural fairness and impartiality are compromised, reaffirming that the cornerstone of arbitration is a fair and equal process.

Finally, the Singapore International Commercial Court (SICC) issued several decisions supporting the arbitral tribunal by granting anti-suit injunctions:

In Cooperativa Muratori v Department of Water Supply & Sewerage Management, the SICC ruled that designating Singapore as the “place of arbitration” implied a choice of seat, thereby affirming the tribunal’s jurisdiction and granted a contractual anti-suit injunction (ASI) against foreign proceedings in Nepal rejecting the sovereign immunity defence. The court clarified and streamlined the requirements for contractual ASI, while also providing guidance on the sovereign immunity defence under the State Immunity Act.

In Novo Nordisk v KBP Biosciences, the SICC granted a worldwide Mareva injunction for the preservation of assets located in Singapore in aid of a New York-seated ICC arbitration. The court held that the ICC emergency arbitrator was unable to grant the injunctive relief requested because one of the defendants was not a party to the arbitration agreement and the process would be considering the urgent risk of dissipation of assets.

Co-written by Johanne Brocas of Pinsent Masons.