In the absence of an express stipulation, what law governs an arbitration agreement? This vexed question, which appeared to be resolved by the English Court of Appeal in SulAmérica Cia Nacional De Seguros SA v Enesa Engenharia SA,1 has resurfaced. In SulAmérica, whilst ultimately characterising the question as one of construction, Moore-Bick LJ held that there should be a presumption in favour of the substantive law governing the contract. This was preferred over a presumption that the law of the seat should apply. In FirstLink Investments Corp Ltd v GT Payment Pte Ltd,2 the Singapore High Court has preferred the latter view and consciously departed from SulAmérica. This question of the implied choice of law (and any attendant presumptions) is significant since parties rarely expressly stipulate the law governing their arbitration agreement; yet, the law governing