Foreign judgments: The limits of transnational issue estoppel, reciprocity, and transnational comity

• Main Author: YEO, Tiong Min
• Format: text
• Language: English
• Published: Institutional Knowledge at Singapore Management University 2021
• Subjects: Foreign judgments; common law; courts; Singapore; Asian Studies; Comparative and Foreign Law; Courts
• Online Access: https://ink.library.smu.edu.sg/sol_research/3727; https://ink.library.smu.edu.sg/context/sol_research/article/5685/viewcontent/ForeignJudgments_2021.pdf
• Institution: Singapore Management University

In Merck Sharp & Dohme Corp v Merck KGaA [2021] SGCA 14, a full bench of the Singapore Court of Appeal addressed the limits of transnational issue estoppel in Singapore law, and flagged possible fundamental changes to the common law on the recognition and enforcement of foreign judgments in Sing...