Which law should govern the 'arbitrability' of a dispute in England?

This article examines, from an English law perspective, which law should govern the arbitrability of disputes at the preaward stage, focusing on the recent Singapore Court of Appeal decision in *Anupam Mittal v Westbridge Ventures II Investment Holdings*. The Singapore court adopted a composite approach requiring disputes to be arbitrable under both the law of the seat of arbitration and the law applicable to the arbitration agreement. By contrast, the article argues that English law should follow the orthodox approach of applying the law of the seat (curial law) alone, ensuring consistency with postaward enforcement under the New York Convention and avoiding complications arising from the UK Supreme Court's decision in *Enka v Chubb*. The article critiques the composite approach for conflating issues of consent and public policy, potentially allowing foreign laws to unduly disrupt English-seated arbitrations, and supports reform of the Arbitration Act 1996 to clarify that arbitrability is governed by the law of the seat, preserving England's status as a pro-arbitration jurisdiction.