Publication Type

Journal Article

Version

acceptedVersion

Publication Date

7-2018

Abstract

The advent of the Singapore International Commercial Court (SICC) and the enactment of the Hague Convention on Choice of Court Agreements 2005 (the Hague Convention) in Singapore presents an intriguing case study of the issues raised by the co-mingling of the rules of an international convention, jurisdictional rules for an international commercial court, and traditional common law jurisdictional principles within the private international law and procedural rules of a single national jurisdiction. This article highlights several key issues raised by the interaction between the SICC, Hague Convention, and common law jurisdictional rules, and proposes solutions to streamline these three sets of rules into a coherent and principled body of law. In addition, this article examines the experience of the Dubai International Financial Centre 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

Last Page

147

ISSN

0261-9261

Publisher

Sweet and Maxwell

Embargo Period

5-3-2021

Additional URL

https://ssrn.com/abstract=3038583

Download

Share

COinS