Recognition of foreign judgments: proposed amendments in Singapore

As the number of cross-border disputes increase, it is becoming more common for parties to wish to enforce a court judgment issued in one jurisdiction in another jurisdiction.  In April 2019, Singapore’s Ministry of Law issued a public consultation paper on proposed amendments to Singapore’s regime for recognising and enforcing foreign judgments. Read more

Amendments to the Singapore International Commercial Court Regime to strengthen Singapore as an international arbitration seat of choice

On 9 January 2018, amendments were passed to the Supreme Court of Judicature (Amendment) Act (“SCJA “) which clarify that the Singapore International Commercial Court (“SICC“) has jurisdiction to hear proceedings relating to international commercial arbitration.  The amendments also abolish the pre-action certificate procedure for applications to the SICC. Established in 2015 as the ‘international’ … Read more

Forum Election, Forum Non Conveniens and the Singapore International Commercial Courts

In its recent decision in Rappo v. Accent Delight International Ltd and another [2017] SGCA 27, the Singapore Court of Appeal considered the distinction and relationship between the doctrines of forum election and forum non conveniens.  Notably, the Court also considered whether the potential availability of the Singapore International Commercial Court (“SICC“) represents a relevant … Read more

Hague Convention on Choice of Courts comes into operation in Singapore

The Hague Convention on Choice of Court Agreements (Hague Convention) officially came into force on 1 October 2016 and there are currently 30 signatory states, including all members of the European Union and Mexico.  As we have previously reported, Singapore became a signatory to the Hague Convention on 25 March 2015.  Subsequently, Singapore ratified the … Read more

Recognition of foreign insolvencies at common law: Singapore sets COMI precedent

For the first time, a court has adopted the ‘centre of main interest’ (COMI) as grounds at common law to recognise foreign insolvency proceedings. The decision earlier this year by the High Court of Singapore (the Court) recognised a Japanese bankruptcy trustee appointed to companies incorporated in the British Virgin Islands (BVI): which primarily operated … Read more

Singapore takes steps toward ratifying Hague Convention on Choice of Court Agreements

In our previous article, we discussed Singapore's signing of the Hague Convention on Choice of Court Agreements (the Convention) on 25 March 2015 and the likely effect this would have on the Singapore International Commercial Court (SICC) and Singapore's profile as a regional and global centre for dispute resolution. On 4 April 2016, Singapore tabled the Choice … Read more

Trends in choice of governing law & jurisdiction in cross-border transactions in Asia: Singapore Academy of Law publishes study

On 10 January 2016, the Singapore Academy of Law (SAL) published the results of its study on preferences for the choice of governing law and jurisdiction made by those involved in cross-border transactions "in Singapore and the region" (the Study).  The Study, which was commissioned by the SAL's International Promotion of Singapore Law Committee, reflects the … Read more