Speech by Senior Minister of State, Ministry of Law and Ministry of Transport Murali Pillai SC at the Bahrain International Commercial Court Conference

His Excellency Shaikh Khalid bin Ali Al Khalifa, Deputy Chair, Supreme Judicial Council, and President, Court of Cassation, Bahrain

The Honourable Chief Justice Sundaresh Menon, Supreme Court, Singapore

Professor Jan Paulsson, President, Bahrain International Commercial Court (BICC)

The Honourable Justice Philip Jeyaretnam, President, Singapore International Commercial Court (SICC)

Your Excellencies, Honourable Justices

Ministers, distinguished speakers, guests, ladies and gentlemen.

Introduction

1. Good afternoon and Marhaba!

2. I am deeply honoured to have this opportunity to deliver this closing address titled “Bilateralism In Action: Singapore-Bahrain”. The good thing about delivering the closing address is that it comes after all the important points that have already been made by eminent speakers, and this occasion is no exception. So the expectations for closing address are usually lower.

3. This is my first time in Bahrain in my current capacity, although I have come previously as a lawyer in private practice. I am grateful for the hospitality that has been shown to my colleagues and I, and struck by the beauty, warmth and openness of Bahrain, and how much the values of our two countries align with one another. I would like to thank our host and look forward to many more meaningful engagements in future.

4. I congratulate the Kingdom of Bahrain on its successful launch of the BICC. It is a significant milestone for both our nations.

5. I looked at the timelines involved, all the way to the launch of the BICC just yesterday. On 20 March 2024, Bahrain and Singapore signed the treaty to set up the BICC and to provide for an appeal to Singapore, by the body designated by the Singapore Government. On 27 August 2024, the royal decree was issued by His Majesty, King of Bahrain, to set up the BICC. On 12 November 2024, I moved the Bill in the Singapore Parliament to provide for appeals to be heard by the International Committee of the SICC, and that Bill was passed on the same day and put into effect the next month. 11 months later, the BICC has been launched.

6. Now amongst us here, we have very experienced policymakers. The speed at which the BICC is launched, figuratively, is equivalent to the speed of a car in a F1 circuit, perhaps like the Bahrain Grand Prix. But I think it is also testimony to the hard work that’s been put in by all who have been involved in this project. I want to join Honourable Chief Justice of Singapore to congratulate everyone who’s involved in setting it up – it is blood, sweat and tears, for sure. I do hope this pioneering spirit that’s been exemplified by Professor Marike Paulsson and her team would continue because, as was mentioned by many speakers, it’s the start, and good starts are important for the development of any new organisation.

7. I would also add that the speed in which the BICC has been launched, is indicative of the strong support of the governments of Bahrain and Singapore and this backing will ensure that the high expectations placed on the BICC will be met.

8. The unique feature of the BICC is the transnational appeal mechanism that will

(a) support a robust judicial process,

(b) contribute towards creating a coherent body of transnational commercial law jurisprudence, and

(c) advance the notion of a transnational system of justice, which honourable speakers have spoken about today.

9. This framework created by the collaboration between Singapore and Bahrain offers us a glimpse into a possible model for “the future of international commercial courts and transnational justice”.

10. It also demonstrates how bilateral partnerships can create innovative solutions that benefit not just the parties involved, but the larger international legal and business community.

Overview: Bilateralism in Action – Singapore & Bahrain

11. Now, what drove this collaboration?

12. This project would not have come to fruition if not for, in my view, three key factors.

13. One, this collaboration would not have been possible without the longstanding and strong bilateral relationship between Singapore and Bahrain.

14. Two, the creation of this unique pipeline of appeals from the BICC to the International Committee is deeply rooted in our two countries’ shared commitment to advance the rule of transnational commercial law.

15. And three, this collaboration is built upon the recognition of our countries’ potential as important economic nodes and commercial centres in our respective regions, namely MENA – the Middle East and North Africa region, for Bahrain, and ASEAN, for Singapore.

16. Indeed, this SICC-BICC collaboration is truly a culmination of bilateralism in action: rooted in friendship, driven by the rule of law, and shaped by commercial realities.

17. Allow me to elaborate.

Singapore-Bahrain longstanding bilateral relationship

18. Today, we stand at the edge of a world being re-made.

19. The traditional models of multilateralism and globalisation are shifting, and the new world order is one that is increasingly fragmented, fractured, where strong fences create new rivals.

20. Trade is no longer understood by just principles of economic efficiency and comparative advantage.

21. We must now include geo-economic and geo-political intelligence as key considerations in business decisions.

22. Businesses will end up re-ordering around trusted business hubs and nodes, where networks of like-minded countries drive transnational behaviour.

23. In today’s world, now being re-made, the pursuit of justice across nations is vital to all countries, large and small. In this new world, small countries like ours can either resign ourselves to being buffeted by strong winds of war and technology, and be content to diminish into reactionary price-takers, or we can refuse to go onto that dim path and choose instead to seize the day to build bridges and strategic partnerships between like-minded countries. Our two small countries, and many like us, can strive to become building blocks of this new global system. And here, both our countries chose the latter.

24. Singapore and the Kingdom of Bahrain share a common history as maritime trading hubs that have developed into modern, agile island nations.

25. We formally established diplomatic relations on 30 June 1985, and this year marks the 40th anniversary of diplomatic ties between Singapore and Bahrain.

26. Over four decades, our ties have expanded far beyond the political realm, into a multifaceted economic collaboration bridging the regions of Southeast Asia and the Arabian Gulf.

Anchoring trade and investment

27. The bedrock of our strong economic relations lies in the institutions we have built together.

28. The Gulf Cooperation Council-Singapore Free Trade Agreement, which came into force on 1 September 2013, has helped liberalise trade between Singapore and the Gulf Cooperation Council, reducing or eliminating tariffs and increasing predictability for businesses.

29. We also benefit from the bilateral investment treaty and a Comprehensive Agreement for the Avoidance of Double Taxation, signed in 2004, which together help lower barriers and risks, and safeguard our investors.

30. These agreements signal our shared commitment to creating a stable, secure, and predictable environment where our companies can plan for the long term.

Judicial Cooperation

31. In the judicial sphere, our respective Judiciaries have also engaged in bilateral judicial cooperation.

32. In 2023, the Supreme Judicial Council of Bahrain and the Supreme Court of Singapore, as represented by the respective Honourable Chief Justices in front of me, signed a Memorandum of Understanding on Cooperation and a Memorandum of Guidance as to the Enforcement of Money Judgements.

33. These instruments further strengthened ties between our two Judiciaries.

34. In particular, the Memorandum of Understanding affirmed parties’ commitment to exchange experiences, and developed institutional and judicial capacity for the effective resolution of cross-border commercial disputes, and the Memorandum of Guidance sought to establish guiding principles for enforcing money judgments issued by the Courts of one country in the other.

35. Ultimately, it was against this backdrop of trust, friendship, and shared common interests that our countries were able to lay the foundation for developing the framework of the SICC-BICC collaboration.

Shared commitment to advance the rule of law

36. What catalysed the development of the BICC, and framework of appeals to the International Committee of the SICC, was our shared commitment to advancing the rule of transnational commercial law.

37. It is often said that “law follows business” but business follows the commands of justice, writ large in law. The increase in global trade over the last few decades has led to a rise in the internationalisation of cross-border commercial disputes.

38. Furthermore, as I mentioned earlier, the world is in a state of flux with supply chain disruptions, global inflation, and economic instability.

39. In times like these, businesses desperately need to rely on legal certainty and the rule of law to operate with confidence, knowing that contracts can be enforced, debts will be paid, and any disputes will be resolved quickly, impartially and on their merits.

40. In short, in this new world order, we need a new model for ensuring justice across nations, as well as within specific jurisdictions.

41. It is no surprise that the International Commercial Courts (ICCs) have gained prominence over the past two decades to meet these commercial needs.

42. However, there are several ICCs across the world, and businesses are free to pick which ICC to bring their cases and disputes to. Why pick Bahrain? Why pick Singapore?

43. As small states, strategically located within our respective regions, both Singapore and Bahrain have recognised the importance of upholding the rule of law. It is core to the national interests of both our countries and it is this that will enable our ICCs to play a role in the global order.

44. This is because businesses will naturally prefer ICCs which are based in countries which themselves manifest the rule of law.

45. And indeed, this is the case for both Singapore and Bahrain:

(a) The World Justice Project recently placed Singapore 4th in East Asia and the Pacific, and 16th globally, in the 2024 Rule of Law Index.

(b) Likewise, Bahrain topped the list of Arab countries in adherence to law and order, according to the Gallup Law and Order Index in 2025, which measures security and public confidence indicators.

46. In addition to being situated in impartial and effective jurisdictions with strong rule of law, businesses will also be drawn to ICCs that administer justice fairly, efficiently, and with commercial pragmatism.

47. In this regard, the BICC, like the SICC, will have a strong international bench, comprising eminent jurists from both civil and common law jurisdictions, possessing deep expertise to hear international commercial cases.

48. Finally, the appeal mechanism from the BICC to the International Committee of the SICC reinforces the application of an international rule of law, by giving parties confidence in the rigour of the judicial decision-making, and contributing towards the development of transnational commercial jurisprudence in a coherent manner.

49. This shared vision between our countries to advance the rule of international commercial law has indeed played a crucial part in shaping the framework of the SICC-BICC collaboration.

Recognition of our countries’ potential as important economic nodes and commercial centres

50. Finally, this collaboration would not have been possible but for our respective countries recognising our potential as economic nodes within MENA and ASEAN, and centres for commercial dispute resolution.

51. Both regions are well-poised for investment and tremendous economic growth.

(a) In MENA, we see ambitious national visions, rising foreign direct investment, and diversification of MENA economies beyond oil dependency into sectors such as green energy, agri-tech, and digital infrastructure.

(b) In ASEAN, we see the fifth largest economy in the world, a dynamic bloc with a young population, a growing middle class, and increasing urbanisation.

52. Given these opportunities, and Bahrain’s Economic Vision 2030 that is premised on the principles of sustainability; competitiveness; and fairness, the establishment of the BICC in Bahrain, with an avenue of appeals to the International Committee of the SICC in Singapore, is envisioned to play a key role in facilitating trade flows between and through these regions, allowing businesses to tap into this vast economic potential.

53. Businesses from the MENA region will be attracted to bring their disputes to the BICC, a neutral and independent ICC, with a potential avenue of appeal to a similarly reputable designated body in Singapore, the International Committee of the SICC.

54. There is also potential for practitioners, including leading practitioners from Singapore whom I see here today, to advise and provide assurance to MENA businesses looking to expand into Singapore, ASEAN, and even Asia.

55. Both nodes for dispute resolution can grow from strength to strength, together.

56. The establishment of BICC and the International Committee, alongside other dispute resolutions institutions in Bahrain and Singapore such as the Bahrain Chamber for Dispute Resolution, the Singapore International Arbitration Centre, and the Singapore International Mediation Centre, can grow the dispute resolution pie in our respective countries and increase opportunities for all.

57. This recognition of commercial practicalities and opportunities was what our two countries had in mind when we collaborated to establish the framework of the BICC.

Conclusion

58. Let me close with this thought.

(a) In an increasingly divided world, Singapore and Bahrain have chosen to build bridges, to support commerce and trade, two of the oldest human activities which improve lives and allow our civilisations to flourish.

(b) We are both committed to the rule of law. Our commitment is not mere business compliance, but a matter of survival as small states in a world of big powers, which from time to time, flex their muscles.

(c) Rule of law enables us to anchor our sovereignty in a legal, moral universe, and to assert our rights and interests against those many times our size or weight.

59. It is in our DNA, and we share a mission to promote our ideals of transnational justice.

60. The launch of the BICC is more than a milestone – it is a fine example of bilateralism in action.

61. Singapore stands ready to continue this journey with Bahrain.

62. We look forward to deepening our collaboration, learning from each other, and to grow together in the years ahead.

63. If we succeed in building our bridges today, it will not just be a victory for the rule of law in two small states, but a shining model for ensuring justice across the world. For those who are seated here, the work started right in front of your eyes.

64. Thank you very much.

Last updated on 6 November 2025