The impact of the Singapore International Commercial Court and Hague Convention on choice of court agreements on Singapore’s private international law
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, ju...
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| Format: | text |
| Language: | English |
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Institutional Knowledge at Singapore Management University
2018
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| Online Access: | https://ink.library.smu.edu.sg/sol_research/3260 https://ink.library.smu.edu.sg/context/sol_research/article/5207/viewcontent/SSRN_id3038583.pdf |
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| Institution: | Singapore Management University |
| Language: | English |
| Summary: | 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. |
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