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Foreign Judgments: The Limits of Transnational Issue Estoppel, Reciprocity, and Transnational Comity
26 May 2021, 8:40 pm
Written by Professor Yeo Tiong Min, SC (honoris causa), Yong Pung How Chair Professor of Law, Yong Pung How School of Law, Singapore Management University In Merck Sharp & Dohme Corp v Merck KGaA [2021] SGCA 14, a full bench of the Singapore Court of Appeal addressed the limits of transnational issue estoppel in Singapore law, and flagged possible fundamental changes to the common law on the recognition and enforcement of foreign judgments in Singapore. [read post]
3 Jan 2024, 12:08 am
Guest post by Professor Yeo Tiong Min, SC (honoris causa), Yong Pung How Chair Professor of Law, Yong Pung How School of Law, Singapore Management University Merck Sharp & Dohme Corp (formerly known as Merck & Co, Inc) v Merck KGaA (formerly known as E Merck) [2021] 1 SLR 1102, [2021] SGCA 14 (“Merck”), noted previously, is a landmark case in Singapore private international law, being a decision of a full bench of the Court of Appeal setting… [read post]
14 Jun 2019, 2:15 am
In a prior decision, the Court of Appeal in Orchard Capital I Ltd v Ravindra Kumar Jhunjhunwala [2012] SGCA 16, had considered a non-exclusive choice of court clause to be relevant at the very least as a factor in the natural forum test, and that the weight to be accorded to the factor depended on the circumstances of each case. [read post]
28 Dec 2017, 5:31 am
Her hostile work environment claim, however, failed (Pung v. [read post]
20 Mar 2018, 3:19 am
Pung v. [read post]
20 Mar 2018, 3:19 am
Pung v. [read post]
19 Dec 2022, 2:31 am
On 13 December 2022, Saini J heard argument in the case of Smith v Talk Talk Telecom (QB-2020-003019). [read post]