Commercial Conflict of Laws

Understanding of the principles of conflict of laws is essential to lawyers who aim to service the highly globalised and interconnected economy of Singapore. This book deals with the central principles, methodologies, and controversies in the subject, with a focus on topics that are relevant to commercial transactions. It examines the jurisdiction of the Singapore courts (including the Singapore International Commercial Court) in cross-border litigation, the effect of foreign judgments in Singapore, choice of law methodologies and their particular application to contractual and non-contractual obligations and inter vivos property transactions. The common law principles are discussed in the context of the framework of Singapore legislation, including the Choice of Court Agreements Act 2016 (implementing the Hague Convention on Choice of Court Agreements), the refreshed Reciprocal Enforcement of Foreign Judgments Act 1959, as well as the new Rules of Court 2021.