This paper explores the embryonic correlation between International Commercial Courts (“ICCts”) and international commercial arbitrations by taking the Singapore International Commercial Court (“SICC”) as the primary example. It starts by examining the various models of ICCts, which can be classified into three categories: global, national, and hybrid. It then explains how SICC functions, which is the only global ICCt with arbitration-like features. The paper highlights the role of International Judges of the SICC in shaping the future of transnational arbitral justice, which has led to the convergence of not just laws but also of the civil and common-law systems. It then illustrates some of the transformative judgments of the SICC—starting with the recent DNZ v DOA case on intra-EU objections around ECT—which strengthened not only the arbitral landscape in Singapore but also the global arbitral legal order. Finally, we will see how the convergence and divergence of ICCts and international arbitration are shaping the future of transnational commercial justice in an age of anti-globalism.
ASA Bulletin