Comparative Analysis of Arbitration Laws: India, Singapore and UK

Arbitration has gained popularity in the field of dispute settlement amongst the parties to commercial agreements as it enables the settlement of disputes quickly and efficiently. This paper will undertake the task of comparing the arbitration systems of India, Singapore, and the UK, looking into how the same five doctrinal bases of the UNCITRAL Model Law, namely party autonomy, kompetenz-kompetenz, separability, minimal court interference, and finality of awards, have been implemented differently by the statutes of these three countries through legislation and case law. The framework adopted by India will consist of the Arbitration and Conciliation Act, 1996 after taking into account the impact of the 2015, 2019, and 2021 amendments and through landmark cases such as Bhatia International, BALCO, and Amazon v Future Retail. The analysis of Singapore will encompass the International Arbitration Act, 1994 and the Arbitration Act, 2001, supplemented by the SIAC’s 2025 Rules, whereas that of the UK will be based on the Arbitration Act 1996 and the newly enacted Arbitration Act 2025, as well as the role played by the LCIA. The paper will finally identify why Singapore and London continue to rank above India in global arbitration rankings due to the reasons that extend.