Publication Type
Journal Article
Version
acceptedVersion
Publication Date
10-2024
Abstract
This paper considers if there can be said to be an “Asian” body of principles for the recognition and enforcement of foreign judgments. Tapping on the results of a research project which was conducted from 2016 to 2020, it is submitted that the answer to this query is in the negative. However, it is suggested that what marks out the “Asian” approach to private international law is the willingness of Asian countries to look outwards for reform and development and to balance the adoption of international norms against important local norms and objectives. Singapore’s approach to the recognition and enforcement is discussed as a case study of this Asian approach.
Keywords
Foreign judgments, common law rules, Hague Judgments Convention, Hague Choice of Court Agreements Convention, Singapore private international law
Discipline
Comparative and Foreign Law
Research Areas
Asian and Comparative Legal Systems
Publication
Korean Journal of International and Comparative Law
Volume
12
Issue
1
First Page
57
Last Page
72
Identifier
10.1163/22134484-12340187
Publisher
Brill
Embargo Period
10-4-2024
Citation
CHONG, Adeline.
"Asian" principles for the recognition and enforcement of foreign judgments? Singapore as a case study. (2024). Korean Journal of International and Comparative Law. 12, (1), 57-72.
Available at: https://ink.library.smu.edu.sg/sol_research/4516
Creative Commons License
This work is licensed under a Creative Commons Attribution-NonCommercial-No Derivative Works 4.0 International License.