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An act done abroad is actionable as a tort in Singapore if it is both actionable as a tort according to the law of Singapore and the law where the act was done. This double actionability rule which requires actionability by the law of Singapore even though the act in question was done abroad, was first enunciated in the 19th century when proof of foreign law was difficult and unfamiliarity with and perhaps suspicion of foreign law was inevitable. The UK, Australia, and Canada have replaced the rule with a more ‘international’ choice of law rule which reflects changes in communications, trade and cross-border intercourse and makes it easier for a plaintiff to obtain redress in respect of a tort committed abroad. In this report we propose reform of the double actionability rule in Singapore of a fairly similar nature, as well as further reforms with particular reference to the protection of intellectual property (IP) rights by way of torts and related actions.


Comparative and Foreign Law | Torts

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Commercial Law


Law Reform Committee Report

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Singapore Academy of Law

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Creative Commons Attribution-Noncommercial-No Derivative Works 4.0 License
This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 4.0 License.

Additional URL Reform Reports/Attachments/8/reform_of_choice_of_law.pdf