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Justice Philip Jeyaretnam: Keynote address at the 74th Conference of the Pacific Rim Advisory Council
74th Conference of the Pacific Rim Advisory Council
Address
Stability, Neutrality and Comity:The Role of International Commercial Courts Amidst Geopolitical Volatility
Tuesday, 27 October 2026
The Honourable Justice Philip Jeyaretnam*
Judge of the High Court
Supreme Court of Singapore
President, Singapore International Commercial Court
I. Introduction
1. It is a pleasure to be here to deliver this address for the 74th Pacific Rim Advisory Council (“PRAC”) conference. I hasten to add, however, that the main event awaits once I conclude, namely the opportunity for all of you to ask questions of the Chief Justice.
2. PRAC is, of course, no stranger to Singapore; the inaugural PRAC conference was held here in 1987. I personally recall the one held here in 2011 in my first year as managing partner of Rodyk & Davidson LLP. It is particularly meaningful that the conference has returned to our shores this year, when Singapore celebrates two hundred years since the passage of the Second Charter of Justice in 1826. The Second Charter of Justice imported English common law into Singapore, subject to local modifications, and established the Singapore legal system.1 Our courts date from that year too.
3. We also celebrate 61 years of independence this year. During these past decades, we have built on our legal heritage. The strong economic growth of our nation since independence is testament to the importance of the rule of law in providing a reliable and conducive environment for businesses. As Lord Mansfield CJ stated in Vallejo v Wheeler (1774) 1 Cowp 143 at 153, “[i]n all mercantile transactions[,] the great object should be certainty […] Because speculators in trade then know what ground to go upon.”2 Chief Justice Menon recently made a similar point in his NUS Law Bicentennial Lecture on the Rule of Law, highlighting the “practical necessity” of the rule of law in ensuring “stability, trust and freedom from arbitrariness” in Singapore.3
4. It is almost forty years since that inaugural PRAC conference, which took place two years before the Berlin Wall fell. When the Soviet Union dissolved, the end of the last empire standing restored numerous countries to self-determination and nationhood across Europe and Asia. That seismic event appeared to give rise to a unipolar world under the broadly benevolent leadership of the United States and governed by multilateral and multinational organisations such as the United Nations and the World Trade Organisation. However, a decade of military adventurism, financial deregulation and market fundamentalism came to a halt with the global financial crisis, which in turn exacerbated socio-economic inequality and eroded trust in public institutions. Questioning the value and utility of the global rules-based order, nations have looked to unilateral solutions and tactics. There has been increased tension between larger nations and their proxies,4 accelerating talk of de-coupling and de-risking, and multiplying conflict and even outright war.5 Thus, we have found ourselves in a multipolar world, where the most powerful countries, including the United States, do not necessarily see the advantages of multilateralism and global rules. We have entered an age of renewed geopolitical contestation and the assertion of natural spheres of influence for major powers.
5. I will focus on two different legal consequences of geopolitical contestation. The first – and direct – consequence is the growing use of economic sanctions by countries. The second – and indirect – consequence is the adoption of disparate responses to various threats or opportunities that we face, including emerging technologies such as artificial intelligence (“AI”) by different countries or blocs, and in particular, the focus on “AI sovereignty”.
6. Law is a happy profession to practise, because it does well in times of stability and peace, but does even better in times of strife and dispute. Indeed, when trust between traders and businesses frays, the need for neutral methods of dispute resolution increases. For this reason, commercial courts continue to be important, and especially internationally-oriented commercial courts. The Singapore International Commercial Court (“SICC”) is one such court.
II. Sanctions
7. One consequence of this geopolitical disintegration, which has had a significant impact on transnational commerce,6 is the growing use of sanctions. Sanctions have a storied history of being used as a punitive measure against states that deviate from “international standards of conduct”.7 They may attract countermeasures, which force businesses to choose between two states’ sanctions regimes. My focus today, however, is on what legal issues sanctions give rise to, and how sanctions have been dealt with by the Singapore courts.
8. In this connection, I make two points. The first is that even as new sanctions and countermeasures are imposed, the cases in which they feature are nevertheless resolved by the application of well-established principles. Courts must strive to remain neutral fora in applying local sanctions laws or considering the implications of foreign sanctions laws. Second, even so, novel fact patterns presented before the courts occasionally provide timely opportunities to reconsider and tweak existing doctrines. I will touch on anti-suit injunctions and anti-enforcement injunctions as one example.
A. Sanctions in domestic proceedings
9. I begin with a brief look at the various ways in which sanctions-related issues arise in our courts.
10. First, sanctions may be directly relevant in local proceedings where they have been given the force of law, which occurs in the context of UN-approved sanctions. Singapore has enacted the United Nations Act 2001 (2020 Rev Ed) (“UN Act”) to give effect to UN sanctions imposed by the UN Security Council under Art 41 of the UN Charter. The UN Act empowers the Minister to make regulations to give effect to those sanctions and provides criminal penalties for breaches of such regulations.8
11. Our courts have seen prosecutions for breaches of sanctions that have been locally implemented. For example, in Public Prosecutor v Sindok Trading Pte Ltd [2022] 5 SLR 336, the accused had been charged with breach of regulations implementing UN sanctions against North Korea; those sanctions prohibited the supply of luxury goods to North Korea, to discourage North Korean nuclear activities which were said to “[endanger] regional stability”.9
12. The High Court noted that breaches of Singapore’s international obligations (as enacted) would affect Singapore’s international reputation – especially if international reprimands or warnings were issued against Singapore. This would affect our efforts to “foster effective commercial relations with other countries”, and might result in foreign sanctions being imposed, which would negatively impact Singapore’s “economic competitiveness”.10 The effect on Singapore’s reputation and standing brought about by breaches of international obligations enacted under national law was a relevant sentencing factor.
13. In other cases, sanctions may be indirectly relevant, in that they form the backdrop against which disputes arise. A common situation is where sanctions impact contractual performance and a question arises as to what parties’ obligations are when that happens. However, I will describe another situation, where sanctions against one party may make it hard for it to fund legal or arbitral proceedings in the agreed third-party neutral forum. When the proceedings are in arbitration, then Art 32(2)(c) of the UNCITRAL Model Law on International Commercial Arbitration (“Model Law”) requires the tribunal to terminate the arbitral proceedings where they become impossible to continue.11
14. This provision was considered by the Singapore High Court in the recent decision of DRL v DRK [2026] 4 SLR 1. In that case, several countries imposed sanctions on the applicant some two years after the commencement of arbitral proceedings. This resulted in the applicant having its assets frozen and being unable to make or receive international payments. The applicant could not pay the requisite deposits to the arbitral institution and its lawyers, and was unable to comply with the tribunal’s order to furnish security for costs. This situation persisted for over two years, and the tribunal eventually issued a final award terminating the arbitration pursuant to Art 32(2)(c) of the Model Law. The applicant’s application to set aside this award was dismissed by the High Court.
15. The High Court observed that Art 32(2)(c) turns only on “an objective finding of fact” by the tribunal concerning impossibility, and once such a finding is made, the tribunal must terminate the arbitration. The tribunal has no procedural discretion to decide otherwise, and the degree of prejudice occasioned to any party by such termination is irrelevant.12 The specific cause of the impossibility is also irrelevant.13 In this case, the applicant was left without recourse against the respondent since the relevant limitation period had expired even before the tribunal had issued its final award. No matter. The court held that a claimant is obliged to “progress [an] arbitration to an award on the merits, and to do so expeditiously”.14 I leave aside for the moment the development of anti-sanctions regimes in some countries, under which sanctioned businesses can seek recourse, although they may in turn face difficulties in enforcing judgments from that country abroad.
16. Sanctions thus impact the sanctioned entity’s ability to resolve commercial disputes. This is especially so in the case of arbitral proceedings, which are a form of private justice that must be funded by parties along the way. The non-sanctioned entity is of course entitled to justify this by reference to the unfairness of arbitral proceedings being indefinitely prolonged by the inability of the sanctioned entity to deploy funds.
17. The courts, by contrast, offer the possibility of a matter proceeding to determination even when one party is unable to deploy funds. Our Rules of Court 2021 (“ROC 2021”) contain a provision (Order 21 rule 2(6)) that confers on the courts the power to “stay or dismiss any application, action or appeal” if a party “refuses or neglects” to pay any costs ordered. Our courts also have the inherent power to stay or dismiss appeals on account of outstanding costs orders.15
18. In a decision handed down earlier this year, the Court of Appeal held in Owner of the vessel(s) “Chloe V” v UBS AG [2026] 1 SLR 107 that a failure to pay outstanding costs due to a lack of financial resources “might not properly be regarded as refusal or neglect to pay”, and whether one “neglects” to pay may require consideration of whether there was a reasonable excuse to have not paid.16 Crucially, the court also held that even if an appellant has refused or neglected to pay outstanding costs, the court may still allow the appeal to proceed, where the “justice of the case” strongly demands that the appeal be heard.17
19. The discretion of courts to allow a case to proceed despite unpaid costs in certain “extremely limited” cases18 reflects a different approach from arbitrations where proceedings that are impossible to continue – potentially due to unpaid costs – must be terminated. This follows from the role of courts as dispensers of public justice, as opposed to arbitrations which provide a “private and consensual” dispute resolution regime.19
20. I now turn to a specific area that has taken on a new complexion following the increasing prevalence of sanctions and sanctions-related disputes, namely, anti-suit and anti-enforcement injunctions.
B. Anti-suit injunctions and anti-enforcement injunctions
21. Members of the audience will no doubt be familiar with the two broad grounds on which an anti-suit injunction (“ASI”) may be granted. First, ASIs may be granted to restrain breaches of court jurisdiction or arbitration agreements. Such contractual ASIs are generally granted in the absence of strong reasons to the contrary.20 Second, a non-contractual ASI may be granted where, for example, the defendant acted in a vexatious or oppressive manner in pursuing the foreign proceedings.21 In this second category, considerations of comity rise to the forefront.22 Thus, courts have required that the forum should have a “sufficiently close connection” with the dispute in question to justify interfering with the foreign court.23
22. I now propose to consider two issues.
23. First, to what extent can potential breaches of sanctions laws be taken into account for the purposes of determining if a non-contractual ASI should be granted?
24. The English High Court was presented with such an argument in FH Holding Moscow Limited v AO UniCredit Bank & Anor [2025] EWHC 3111 (Comm). In this case, a Cyprus company – which I will refer to as “FH Holding” – whose business operations were solely in Russia faced proceedings in Moscow brought against it by a Russian bank. The bank’s parent company (an Italian bank) was also joined to the Moscow proceedings as a third party. FH Holding applied for an ASI before the English courts. Apart from seeking a contractual ASI (which was not granted by the High Court), FH Holding also argued that an ASI should be granted on a non-contractual basis because if it lost in the Moscow proceedings, there might be a blind auction and that would raise a real risk of its assets being sold to a party sanctioned by the EU.24 It was submitted that FH Holding, being bound by EU sanctions law, would not be able to cooperate with any such sale, and therefore the Moscow proceedings were vexatious or oppressive.
25. The English High Court rejected this argument on the basis that the English courts did not have sufficient interest in the matter. The Moscow proceedings involved a Russian bank pursuing foreclosure proceedings in respect of Russian real property under a Russian law contract with a Russian jurisdiction clause; also, FH Holding operated in Russia.25 On the other hand, the English courts only had a “tenuous” interest in the matter. There was also some evidence that the blind auction would not occur immediately after the Moscow proceedings were concluded. Bearing in mind the requirements of comity,26 an ASI was not granted on the vexatious or oppressive ground. FH Holding did not pursue this argument in its eventual appeal to the English Court of Appeal.27
26. That an ASI was not granted in such circumstances should come as no surprise from the perspective of Singapore legal practitioners. As explained by the Singapore Court of Appeal in BCS Business Consulting Services v Baker, Michael A (executor of the estate of Chantal Burnison, deceased) [2023] 1 SLR 1, the forum court “has no superiority over a foreign court in deciding what the justice between the parties requires”.28 Further, “comity suggests that the foreign court should decide whether the action in that court should proceed”, and there must be good reason to justify an interference with the foreign court’s processes. The mere fact that the outcome of the foreign proceedings may result in breaches of foreign sanctions law is likely to be insufficient to justify granting an ASI.
27. I now turn to the next topic: the court’s power to grant anti-enforcement injunctions (“AEIs”). There has been a rise in the use of AEIs, driven in part by business disruptions caused by conflicts and geopolitical tensions.29 The English courts have granted AEIs where there is evidence that a foreign court will not permit the discontinuance of proceedings even if an ASI has been granted and the party who has commenced the foreign proceedings seeks a discontinuance order.30
28. Whether such an approach will be accepted in Singapore remains an open question. I note, however, that the Court of Appeal has held that exceptional circumstances – for example, fraud – must be shown to justify granting an AEI.31 This is different from the observation of the English Court of Appeal in SAS Institute Inc v World Programming Ltd [2020] EWCA Civ 599 that “there is no distinct jurisdictional requirement that an [AEI] will only be granted in an exceptional case”.32
29. Moving away from the issue of sanctions – which has provided fertile ground for reconsidering and developing various legal doctrines, I now consider a second consequence of geopolitical fragmentation, which relates to regulation of AI companies and their products.
III. Regulatory fragmentation
30. Questions of national security, as well as economic and cultural benefits, have encouraged nations to strive to win the AI race, or at least to independently own and operate AI systems of competitive capability.33 This has led to serious efforts to achieve “AI sovereignty”, which has been defined in a white paper by the World Economic Forum as the “ability of economies to … govern AI ecosystems in accordance with their own values”, through both “localised investment and trusted international collaboration”.34 For example, Singapore’s HTX, a statutory board of the Ministry of Home Affairs, has announced plans to develop its own on-premise AI infrastructure, its own AI models and its own AI applications.35 The UK has launched a venture fund specifically for investing in domestic AI start-ups,36 and many countries have made similar efforts to invest domestically.37
31. At the same time, there is the risk of harm being caused by AI models. Indeed, in recent months, the news has been rife with reports of AI models going rogue, hacking into other companies’ and governments’ websites.38
32. Given the rise of state-backed or even state-owned entities in developing and deploying “sovereign AI”, one question that may eventually emerge in considering the potential liability of such entities for wrongs committed by the AI models that they own is whether they are entitled to state immunity.
33. In Cooperativa Muratori and Cementisti – CMC di Ravenna, Italy v Department of Water Supply & Sewerage Management, Kathmandu [2025] 4 SLR 983, a three-Judge coram of the SICC considered, among a range of other matters, whether an agency, which had been formed by the Government of Nepal to implement a water supply project, was entitled to state immunity. Under s 16(1) of the State Immunity Act 1979 (2020 Rev Ed), the relevant question was whether the agency was a “separate entity” that was “distinct from the executive organs of the government of the State and capable of suing or being sued”; further, the agency would only be immune from the jurisdiction of the courts in relation to things done “in the exercise of sovereign authority”. In that case, despite being a “separate entity”, the agency had not exercised sovereign authority because it had only entered into a commercial transaction for the provision of services in respect of the water supply project.39 This generally involved an application of familiar state immunity principles.
34. However, it may not always so be clear that an entity is “distinct from the executive organs of the government of the State”. I have already mentioned countries’ efforts to develop – and release for public use – their own AI systems. Novel situations call for the nuanced and sophisticated application or adjustment of established legal doctrines.
IV. International Commercial Courts and the SICC’s unique contribution
35. Having sketched out several legal issues that may arise given increased geopolitical contestation and regulatory fragmentation, this is an appropriate juncture for me to turn to the important role performed by international commercial courts.
36. International commercial courts respond to the need for neutral and expert fora to resolve disputes arising from cross-border transactions.40 Courts typically hold hearings in public and arrive at public decisions for which they give reasons. This means that judgments on matters of an “international and commercial nature”41 can be consulted by the profession, by businesses and by the public at large. This is different from arbitral awards which are rarely published and lack precedential value. Such awards also typically do not contain detailed and sustained discussions of the law. Publicly determining and ruling on business disputes is especially crucial as both technology and business practices change and evolve.42
37. The SICC is uniquely organised to address complex cross-border disputes, including when parties may not have any connections to Singapore apart from having selected Singapore as the neutral forum. There can be no doubt that even back in 1987, when the inaugural PRAC conference was held, Singapore had a strong commercial bench which decided matters in the English language, and had the confidence of foreign investors. Even so, a key “organi[s]ational innovation”43 is that the SICC comprises both Singapore commercial judges and non-Singapore commercial judges drawn from leading common law and civil jurisdictions.44 This is of particular utility when cross-border disputes require the application of foreign laws and principles of conflict of laws. It is also helpful and efficient that parties before the SICC can apply for a question of foreign law to be determined based on submissions from lawyers instead of proof by expert witnesses.45 The SICC thus hears submissions from foreign lawyers – often from more than one jurisdiction – regularly.
38. Second, it is worth emphasising that Singapore judgments travel easily across jurisdictions. The SICC’s judgments as Singapore court judgments46 are enforceable around the world by one or more methods of enforcement. This includes enforcement under the Hague Convention on Choice of Court Agreements, through reciprocal enforcement statutes, in common law countries by common law actions on the judgment debt and in civil law countries by enforcement procedures predicated on presumed reciprocity.47
V. Conclusion
39. In closing, I step back to suggest a broader question for reflection: what is the role that Singapore can play in the legal sphere in a geopolitically fragmented world? Two points are of note.
40. First, beginning at home, the different branches of government proactively ensure that Singapore remains a stable and reliable partner in a geopolitically fragmented world. For example, the Singapore Judiciary participates in initiatives that promote court-to-court cooperation, such as the Judicial Insolvency Network. Meanwhile, the Singapore executive and legislature continue to pursue the adoption of internationally developed model laws that seek to achieve harmonisation in specific areas, as seen by the Ministry of Law’s acceptance of a proposal to adopt the UNCITRAL Model Law on Enterprise Group Insolvency and the UNCITRAL Model Law on Recognition and Enforcement of Insolvency-Related Judgments.48
41. Second, looking abroad, international commercial courts anchor the system of justice for businesses operating across borders. In so doing, international commercial courts may operate in collaboration with one another. This is illustrated by the treaty between the Bahraini and Singapore governments establishing the Bahrain International Commercial Court, with a designated appeal mechanism to the International Committee of the SICC.49
42. I began my speech with the topic of our courts’ Bicentennial celebrations and the importance of certainty in commercial dealings. The more geopolitical conflict there is, the more businesses will need the legal profession, as well as neutral and expert methods of dispute resolution, such as may be found in international commercial courts.
43. And now to the main event!
* I gratefully acknowledge the assistance of JLC Jared Foong and JLC-D Bryan Goh in the preparation of this Address.
1 Thio Li-Ann, A Treatise on Singapore Constitutional Law (Academy Publishing, 2012) at para 2.073; Goh Yihan and Paul Tan (gen ed), Singapore Law: 50 Years in the Making (Academy Publishing, 2015) at para 1.7.
2 This quotation has also been cited in various cases: see, for example, Quoine Pte Ltd v B2C2 Ltd [2020] 2 SLR 20 at [184] (Jonathan Mance IJ dissenting); Patel v Mirza [2017] AC 467 at [113] (Lord Toulson JSC).
3 Chief Justice Sundaresh Menon, “Evolving Conceptions of the Rule of Law: The Singapore Experience” (Speech delivered at the NUS Law Bicentennial Lecture on the Rule of Law, on 2 September 2026).
4 Chan Chun Sing, “Singapore Amid Great Power Rivalry” (41st IISS-Asia Fullerton Lecture delivered on 9 November 2021); see also Financial Times, “Xi, Trump and the Thucydides Trap” (16 May 2026).
5 Peace Research Institute Oslo, “Conflicts between states highest level since World War II” (8 June 2026).
6 See Justice Steven Chong, “Sanctions: Between a Rock and a Hard Place” (Speech delivered at the Singapore Shipping Law Forum 2024, on 17 October 2024).
7 Lance Davis and Stanley Engerman, “History Lessons: Sanctions: Neither War nor Peace” (2003) 17(2) The Journal of Economic Perspectives 187.
8 Sections 2 and 5–6 of the United Nations Act 2001 (2020 Rev Ed).
9 Public Prosecutor v Sindok Trading Pte Ltd [2022] 5 SLR 336 (“Sindok Trading”) at [3] and [39].
10 Sindok Trading at [40]–[43].
11 First Schedule to the International Arbitration Act 1994 (2020 Rev Ed).
12 DRL v DRK [2026] 4 SLR 1 (“DRL v DRK”) at [55] and [57].
13 DRL v DRK at [77].
14 DRL v DRK at [58].
15 Owner of the vessel(s) “Chloe V” v UBS AG [2026] 1 SLR 107 (“Chloe V”) at [30].
16 Chloe V at [35].
17 Chloe V at [36].
18 Chloe V at [36].
19 DRL v DRK at [46].
20 Finaport Pte Ltd v Techteryx Ltd [2025] 1 SLR 1236 at [39], citing Sun Travels & Tours Pvt Ltd v Hilton International Manage (Maldives) Pvt Ltd [2019] 1 SLR 732 (“Sun Travels”) at [68].
21 Evergreen International SA v Volkswagen Group Singapore Pte Ltd [2004] 2 SLR(R) 457 at [15] and [32].
22 Lakshmi Anil Salgaocar v Jhaveri Darsan Jitendra [2019] 2 SLR 372 (“Lakshimi”) at [129].
23 Lakshmi at [106]–[113].
24 FH Holding Moscow Limited v AO UniCredit Bank & Anor [2025] EWHC 3111 (Comm) (“FH Holding (HC)”) at [63].
25 FH Holding (HC) at [66].
26 FH Holding (HC) at [65].
27 FH Holding Moscow Limited v AO Unicredit Bank & Anor [2026] EWCA Civ 468 at [26].
28 BCS Business Consulting Services v Baker, Michael A (executor of the estate of Chantal Burnison, deceased) [2023] 1 SLR 1 at [74].
29 Yeo Tiong Min, “The Rise of Anti-Enforcement Injunctions” (Keynote Address delivered at SICC Seminar 2026, on 13 January 2026) at para 26.
30 Maxamcorp International SL v Eurotel LLC [2026] EWHC 666 (Comm) at [94]; JP Morgan Securities Plc v VTB Bank PJSC [2025] EWHC 1368 (Comm) (“JP Morgan”) at [167]; Barclays Bank plc v PJSC Sovcombank [2024] EWHC 1338 (Comm) at [14]; Airbus Canada Ltd Partnership v Joint Stock Company Ilyushin Finance Co [2024] EWHC 790 (Comm) at [24]; Deutsche Bank AG v RusChemAlliance LLC [2023] EWCA Civ 1144 at [43]. The appeal against the decision in JP Morgan was dismissed by the Court of Appeal in VTB Bank PJSC v JP Morgan Chase Bank [2026] EWCA Civ 589, without further comment on the scope of granting AEIs.
31 Sun Travels at [98]–[101].
32 SAS Institute Inc v World Programming Ltd [2020] EWCA Civ 599 at [93], cited in JP Morgan Securities Plc v VTB Bank PJSC [2025] EWHC 1368 (Comm) at [167].
33 Carnegie Endowment for International Peace, “Early Lessons in the Pursuit of Sovereign AI” (17 June 2026).
34 World Economic Forum, “Rethinking AI Sovereignty: Pathways to Competitiveness through Strategic Investments” (White Paper, January 2026).
35 Janna Giam, “Why Sovereign AI is Key to Scaling Public Safety Impact” (HTX, 8 June 2026).
36 Yahoo Finance, “UK Announces Sovereign AI Fund to Fast-track Domestic AI Startups” (20 April 2026).
37 Center for Security and Emerging Technology, “Assessing Sovereign AI: A Two-Pronged Framework” (4 August 2026).
38 See, for example, NBC News, "OpenAI Agents Hacked Hugging Face in 700-strong Swarm, Tried to Cover Tracks, Investigations Find" (27 August 2026); The Guardian, “Google Says Its Gemini AI Model Hacked Three Other Companies” (19 September 2026); The Wall Street Journal, “OpenAI Agents Hit U.S. Government Websites” (25 September 2026); Reuters, “OpenAI Apologises for Australian Government Website Hack, Pledges to Rebuild Trust” (29 September 2026); The Washington Post, “AI Agents Tried to Hack a Canadian Government Website, Researchers Say” (30 September 2026).
39 Cooperativa Muratori and Cementisti – CMC di Ravenna, Italy v Department of Water Supply & Sewerage Management, Kathmandu [2025] 4 SLR 983 at [54]–[57].
40 Georgios Dimitropoulos and Stavros Brekoulakis, “International Commercial Courts: The Future of International Adjudication – An Introduction” in International Commercial Courts: The Future of Transnational Adjudication (Stavros Brekoulakis and Georgos Dimitropoulos eds, CUP, 2022) at pp 10–17.
41 As is the case for the SICC: see s 18D(1)(a) of the Supreme Court of Judicature Act 1969 (2020 Rev Ed).
42 See, for example, Christopher Grout and Sir William Blair, “The Role of International Commercial Courts in Commercial Dispute Resolution” in International Commercial Courts: The Future of Transnational Adjudication (Stavros Brekoulakis and Georgos Dimitropoulos eds, CUP, 2022) at pp 42–45.
43 Georgios Dimitropoulos and Stavros Brekoulakis, “International Commercial Courts: The Future of International Adjudication – An Introduction” in International Commercial Courts: The Future of Transnational Adjudication (Stavros Brekoulakis and Georgos Dimitropoulos eds, CUP, 2022) at p 14.
44 Justice Philip Jeyaretnam, “Overview” in Charting New Waters: The Singapore International Commercial Court After Ten Years (Justice Philip Jeyaretnam and Francis Xavier SC eds, Academy Publishing, 2025) at p 51.
45 O 16 r 8(1) of the Singapore International Commercial Court Rules 2021; see also Stanley Lai SC, “Foreign Law, Foreign Lawyers” in Charting New Waters: The Singapore International Commercial Court After Ten Years (Justice Philip Jeyaretnam and Francis Xavier SC eds, Academy Publishing, 2025).
46 David Joseph KC, Afzal Ali and Joshua Hiew, “Enforcement in the Singapore International Commercial Court” in Charting New Waters: The Singapore International Commercial Court After Ten Years (Justice Philip Jeyaretnam and Francis Xavier SC eds, Academy Publishing, 2025) at pp 244–245.
47 Report of the Singapore International Commercial Court Committee, 29 November 2013, at paras 42–51; see also David Joseph KC, Afzal Ali and Joshua Hiew, “Enforcement in the Singapore International Commercial Court” in Charting New Waters: The Singapore International Commercial Court After Ten Years (Justice Philip Jeyaretnam and Francis Xavier SC eds, Academy Publishing, 2025) at pp 251–257.
48 Ministry of Law, “Acceptance of Recommendations by the Committee to Enhance Singapore’s Corporate Restructuring and Insolvency Regime Following Public Consultation” (14 May 2026).
49 Chief Justice Sundaresh Menon, “The Emerging Architecture of Transnational Commercial Justice” in Charting New Waters: The Singapore International Commercial Court After Ten Years (Justice Philip Jeyaretnam and Francis Xavier SC eds, Academy Publishing, 2025) at pp 14–15.
2026/11/02
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