1. This article explores the origins and development of the statutory regime governing arbitrations in Singapore. It will consider its unified origins when no distinction was drawn between domestic and international arbitrations to the rationale for the current reliance on such a distinction and the UNCITRAL Model Law. The historical and drafting bases of the early regimes were linked principally to developments in the United Kingdom. This paper will examine the move away from this to the Model Law drafted by UNCITRAL in the mid-1980s and analyse the structure and operation of, as well as recent cases dealing with, the statutory regime. The article will consider the primary basis on which Singapore adopted the Model Law. It will also analyse the “localisation” of many of the broad principles outlined in the Model Law to fit in with the jurisprudence of the common law system in Singapore. The article considers the role played by key commercial objectives which were important considerations behind the adoption of the Model Law.

2. The article will also consider (briefly and only by way of an outline) the current situation in Malaysia (paragraphs 210 et seq. ) and the steps underway to revise the existing statutory regime. However as these are matters in a state of flux with no draft Bill before Parliament, it is not possible to analyse the changes with any degree of precision. It is, therefore, a necessarily brief analysis of the position.

3. The origins of Singapore statutory law on arbitration can be traced all the way back to the turn of the nineteenth century in the form of the

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