The Impact of the Singapore International Commercial Court and Hague Convention on Choice of Court Agreements on Singapore’s Private International Law
(2018) 37(1) Civil Justice Quarterly 124
21 Pages Posted: 29 Nov 2017 Last revised: 8 Jan 2018
Date Written: 2017
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 Courts to elucidate lessons for the development of the SICC’s jurisdictional rules.
Keywords: DIFC, DIFC Courts, conflict of laws
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