Singapore High Court rejects jurisdictional objection to enforcement of international arbitration awards made in Singapore | Practical Law
In a much anticipated decision, the Singapore High Court refused to entertain a jurisdictional objection to the enforcement of a domestic international arbitration award (an international arbitration award made in Singapore) to the value of over US$250million. The court held that the award debtor was precluded from challenging the arbitral tribunal’s jurisdiction at the enforcement stage, in circumstances where the tribunal ruled, as a preliminary question, that it had jurisdiction and where the award debtor did not appeal from that ruling and proceeded to contest the substantive claims in the arbitration. The court examined the scope of parties’ powers to resist the enforcement of international arbitration awards in Singapore and the differences in approach to the curial oversight of international arbitration between Singapore, the UNCITRAL Model Law and civil law jurisdictions on the one hand, and the United Kingdom on the other.