Under Section 7(3) and (4), which form of communication does NOT constitute "writing" for a valid arbitration agreement? 

Section 7(3) mandates: "An arbitration agreement shall be in writing." Section 7(4) defines "in writing" to include: (a) documents signed by parties; (b) exchange of letters, telex, telegrams, or other means of telecommunication including electronic means providing a record; or (c) exchange of statements of claim and defence where existence is alleged and not denied. The critical requirement is a record of agreement—oral agreements, even if later memorialized in writing, are not recognized because the original agreement lacked documentary form. An oral statement before witnesses lacks the essential evidentiary certainty that writing provides.