Publication Type

Journal Article

Version

publishedVersion

Publication Date

7-2018

Abstract

The advent of the Singapore International Commercial Court (SICC) and the enactment of the Hague Convention on Choiceof Court Agreements 2005 (the Hague Convention) in Singapore presents an intriguing case study of the issues raised by theco-mingling of the rules of an international convention, jurisdictional rules for an international commercial court, andtraditional common law jurisdictional principles within the private international law and procedural rules of a singlenational jurisdiction. This article highlights several key issues raised by the interaction between the SICC, HagueConvention, and common law jurisdictional rules, and proposes solutions to streamline these three sets of rules into acoherent and principled body of law. In addition, this article examines the experience of the Dubai International FinancialCentre Court to elucidate lessons for the development of the SICC’s jurisdictional rules.

Keywords

private international law, conflict of laws, Singapore International Commercial Court

Discipline

Courts | International Law

Research Areas

Corporate, Finance and Securities Law

Publication

Civil Justice Quarterly

Volume

37

Issue

1

First Page

124

ISSN

0261-9261

Publisher

Sweet and Maxwell

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