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8 Choice of Law for Torts

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: 26 February 2024

Applicable law — Concurrent claims — Tort/delict — Damages

This chapter explains how Singapore's choice of law rule for torts largely reflects the English common law rule of double actionability. As a general rule, the tort choice of law rule requires actionability under the lex fori and actionability under the law of the place where the wrongful act was committed. This general rule is subject to a flexible exception which may be invoked to apply the law that has the most significant relationship to the parties and the occurrence. It then examines possible reforms for the double actionability rule and the possible issues surrounding torts, such as the relevance of party autonomy, internet defamation and the interrelation between contract and tort choice of law issues.

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