ABSTRACT

International commercial arbitration (ICA) has become much more important for Asia since the 1990s. New arbitration centres in the region, often with direct or indirect financial support from the government, attract growing caseloads (Nottage and Garnett 2010a). This development is supported by widespread accession to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (NYC: 330 UNTS 3), 2 and the highest adoption rate for the UNCITRAL Model Law on International Commercial Arbitration (Greenberg, Kee and Weeramantry 2010: 36). Courts throughout Asia, despite some significant exceptions, 3 have generally come to uphold ICA's core principles – respecting arbitral proceedings and the awards they generate.