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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2018
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sg-smu-ink.sol_research-52072021-05-04T03:28:31Z The impact of the Singapore International Commercial Court and Hague Convention on choice of court agreements on Singapore’s private international law CHNG, Wei Yao, Kenny 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. 2018-07-01T07:00:00Z text application/pdf https://ink.library.smu.edu.sg/sol_research/3260 https://ink.library.smu.edu.sg/context/sol_research/article/5207/viewcontent/SSRN_id3038583.pdf http://creativecommons.org/licenses/by-nc-nd/4.0/ Research Collection Yong Pung How School Of Law eng Institutional Knowledge at Singapore Management University private international law conflict of laws Singapore International Commercial Court Courts International Law |
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private international law conflict of laws Singapore International Commercial Court Courts International Law CHNG, Wei Yao, Kenny The impact of the Singapore International Commercial Court and Hague Convention on choice of court agreements on Singapore’s private international law |
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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. |
format |
text |
author |
CHNG, Wei Yao, Kenny |
author_facet |
CHNG, Wei Yao, Kenny |
author_sort |
CHNG, Wei Yao, Kenny |
title |
The impact of the Singapore International Commercial Court and Hague Convention on choice of court agreements on Singapore’s private international law |
title_short |
The impact of the Singapore International Commercial Court and Hague Convention on choice of court agreements on Singapore’s private international law |
title_full |
The impact of the Singapore International Commercial Court and Hague Convention on choice of court agreements on Singapore’s private international law |
title_fullStr |
The impact of the Singapore International Commercial Court and Hague Convention on choice of court agreements on Singapore’s private international law |
title_full_unstemmed |
The impact of the Singapore International Commercial Court and Hague Convention on choice of court agreements on Singapore’s private international law |
title_sort |
impact of the singapore international commercial court and hague convention on choice of court agreements on singapore’s private international law |
publisher |
Institutional Knowledge at Singapore Management University |
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2018 |
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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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