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5 The Recognition and Enforcement of Foreign Judgments

Adeline Chong, Man Yip

From: Singapore Private International Law: Commercial Issues and Practice

Adeline Chong, Yip Man

From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2023. All Rights Reserved.date: 15 April 2024

Subject(s):
Enforcement of foreign judgments — Choice of court and jurisdictional agreements — Jurisdiction under the Common Law Rules

This chapter discusses the four regimes for the recognition and enforcement of foreign judgments in Singapore. The regimes include the Reciprocal Enforcement of Commonwealth Judgments Act 1921 (RECJA), the Reciprocal Enforcement of Foreign Judgments Act 1959 (REFJA), the Choice of Court Agreements Act 2016 (CCAA), and the common law rules. The chapter considers the RECJA and REFJA which are modelled on common law rules. The Singapore government's concerted efforts to liberalize its foreign judgment rules resulted in the enactment of the Hague Convention on Choice of Court Agreements to enhance the enforceability of Singapore International Commercial Court judgments in other countries. This chapter briefly looks at the Hague Judgments Convention which employs indirect rules on jurisdiction and sole grounds on which a foreign judgment may be refused recognition or enforcement. The chapter also covers the grant of an injunction against the enforcement of a foreign judgment and the enforcement of international mediated settlement agreements through the Singapore Convention on Mediation.

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