[2014] SGHCR 12

“law must, in the absence of an unmistakable intention to the contrary, govern the arbitration agreement. Singapore took a different approach. In FirstLink Investments Corp Ltd v GT Payment Pte Ltd [2014] SGHCR 12, the learned Senior Assistant Registrar held that in the absence of an express choice of the law governing”

“ded to the law of the seat of the arbitration in determining the parties’ implied choice of law. In this regard, the plaintiff relies on FirstLink Investments Corp Ltd v GT Payment Pte Ltd and others [2014] SGHCR 12 (“FirstLink”), which, it claims, represents the law in Singapore.”

“table presumption that the implied choice would be the expressly chosen law of the substantive contract (at [26]). On the other hand, in FirstLink Investments Corp Ltd v GT Payment Pte Ltd and others [2014] SGHCR 12 (“FirstLink”), the Court took the position that in a competition between an expressly chosen substantive”