Case: Paulus Tannos v Heince Tombak Simanjuntak and others [2020] SGCA 85 – majority of Court of Appeal refused recognition of foreign bankruptcy order due to breach of natural justice

Singapore Law; Legal; Lawyer

Significance: In a rare split decision, the majority of the Court of Appeal (Sundaresh Menon CJ and Tay Yong Kwang JA; Woo Bih Li J dissenting) refused recognition of foreign bankruptcy order due to breach of natural justice.

The majority found that the evidence did not prove that:

(i) notices of the bankruptcy application in Indonesia were properly served on the appellants;

(ii) the appellants had actual knowledge of the bankruptcy proceedings but chose not to appear in them.

The appellants were thus deprived of the opportunity to challenge validity of service or liability under the guarantees and object to the making of the bankruptcy orders.

The Court left open the issue of the correctness of the legal principles on recognition of foreign bankruptcy orders: at [22].

Supreme Court case summary found here.

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Shi Wen Yue v Shi Minjiu and another [2016] SGHCR 8 – HC AR holds Chinese judicial settlement enforceable

Singapore Law; Legal; Lawyer

Shi Wen Yue v Shi Minjiu and another [2016] SGHCR 8 – AR holds that PRC judicial settlement enforceable not as a foreign judgment but an agreement

Significance: An AR exercising powers as a High Court judge held that a mediation paper / judicial settlement made in Chinese proceedings pursuant to a settlement could be enforced in the Singapore court not as a foreign judgment based on the application of the laws of China, but an agreement under the common law.