"Asian" principles for the recognition and enforcement of foreign judgments? Singapore as a case study

• Main Author: CHONG, Adeline
• Format: text
• Language: English
• Published: Institutional Knowledge at Singapore Management University 2024
• Subjects: Foreign judgments; common law rules; Hague Judgments Convention; Hague Choice of Court Agreements Convention; Singapore private international law; Comparative and Foreign Law
• Online Access: https://ink.library.smu.edu.sg/sol_research/4516; https://ink.library.smu.edu.sg/context/sol_research/article/6474/viewcontent/Are_there_Asian_Principles_for_the_REFJs__KJICL___updated_AC_01102024_.pdf
• Institution: Singapore Management University

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.