Recently, a dozen or so lawyers from China attended a training course at the Singapore Mediation Centre, then sat the accreditation examination, which was conducted entirely in English. The Hong Kong Special Administrative Region has its own mediation bodies, its own English-language legal tradition, its own accreditation schemes. So why did those lawyers go to Singapore and not Hong Kong?

The knee-jerk answer is that Singapore has out-marketed Hong Kong. But that easy answer misses a bigger and more important consideration, one that has little to do with which city “wins” and a great deal to do with what each city, and the Chinese mainland itself, is good at doing.

Consider what China has been building in this area. In 2018, the Supreme People’s Court set up the China International Commercial Court, with branches in Beijing, Shenzhen and Xi’an. The idea is simple: Bring mediation, arbitration and litigation together under one roof, so a dispute between a Chinese company and a foreign one, arising inside China, can be settled inside China by a bench that includes judges with genuine international experience. Add to that the International Organization for Mediation, the new intergovernmental body that opened its headquarters in the Hong Kong Special Administrative Region last October, and the picture becomes clear. China is no longer content to let disputes between Chinese and foreign parties be settled somewhere else. It is building the machinery to handle them at home. Mediation settlement is not about deciding who is right or wrong. It is about finding a solution both parties are comfortable with. A dispute between a foreign entity and a Chinese entity being mediated in English will be more comfortable for the foreign entity.

Hong Kong’s economic territory lies one step further out — in the Guangdong-Hong Kong-Macao Greater Bay Area, and in the currency that increasingly moves through it. The “one country, two systems” framework gives Hong Kong an advantage that is not available anywhere else in the region: a common law system that the mainland trusts. Since 2020, companies operating in the Qianhai zone in Shenzhen have been able to choose Hong Kong law and a Hong Kong arbitration seat for their disputes; this was widened to cover more Greater Bay Area cities in February last year. There is a joint mainland-Hong Kong mediation center, an investment-dispute mechanism dating back to 2017, and a new cross-border online platform launched in 2024 for Belt and Road cases. Singapore has none of this. It all hinges on the constitutional relationship that only Hong Kong has with the mainland.

Then there is money. Hong Kong is still, by a wide margin, the world’s largest offshore hub for the renminbi — commonly cited figures put its share of offshore RMB payment at around 75 percent, well ahead of London and Singapore, with a liquidity pool of roughly 1 trillion yuan ($149 billion) sitting in its banks. As the yuan becomes more international, so will the disputes involving transactions denominated in it. Where else would those disputes naturally go, if not to the city that already prices and clears the currency at scale?

Singapore’s own territory faces a different way entirely. It has long been the obvious seat for disputes across Southeast Asia. But its more natural growth lies toward India. The Singapore International Arbitration Centre now counts India as one of its top three sources of foreign cases, Indian law as its third most commonly applied governing law, and Indian among its most frequently appointed arbitrators. This should not surprise anyone who knows Singapore. Close to one in 10 Singaporeans is of Indian descent, a community with deep commercial and family roots across the subcontinent, and Singapore has had a comprehensive economic partnership with India for two decades. As India’s own companies do more business abroad, Singapore is placed, by blood as much as by policy, to be their natural gateway.

Here is the point. A dispute between a German manufacturer and its Chinese joint-venture partner, arising in the mainland, belongs in the mainland. A dispute over a Greater Bay Area supply contract, or an offshore yuan bond, belongs in Hong Kong. A dispute between an Indian company and its Southeast Asian partner belongs in Singapore. These are not three jurisdictions chasing the same piece of business. They are three jurisdictions, each holding a different piece of a much larger whole.

There is an old story, told in more than one culture, of blind men who each touch a different part of an elephant and each insist they have found the whole animal. The one holding the trunk swears it is a snake; the one leaning on a leg insists it is a tree; the one at the ear maintains it is a fan. Each is right about his own part, and wrong about the whole. Hong Kong and Singapore, in their competition over which city trains more mediators, risk the same mistake — mistaking their own corner of the elephant for the entire animal.

The Chinese have their own way of putting this: Three cobblers, pooling their wits, are said to be worth that of Zhuge Liang (181-234), the great strategist of the Three Kingdoms. No single one of the mainland, Hong Kong, and Singapore needs to be Zhuge Liang. Put together, sensibly, they could be.

None of this means Hong Kong should stop competing. It should compete harder — matching Singapore’s outreach into the mainland’s law schools and arbitration commissions, and matching its caseload, not merely its ambitions. Healthy competition sharpens institutions, and Hong Kong has real ground to make up. But the mainland lawyers’ training in Singapore recently was not a defeat for Hong Kong; neither is the China International Commercial Court a defeat for Singapore, nor the headquarters of the new mediation body in Hong Kong a defeat for Singapore. Each was simply another piece of the “elephant”, found by the hand best placed to find it. Whether the mainland, Hong Kong and Singapore choose to put those pieces together — through referral agreements, shared training, mutual recognition of each other’s mediators — is now the only question worth asking. Get that right, and Asia, not London or Geneva, becomes where the world sends its disputes to be settled.

The author is a retired physician and a mediator accredited by the Singapore Mediation Centre.

The views do not necessarily reflect those of China Daily.