Thou Shalt Not Sue? Recent Developments to the Scope of Anti-suit Injunctions in Singapore and England
This article analyses two recent developments in the law relating to anti-suit injunctions to enforce arbitration agreements: (i) the first stems from the decision of the Singapore International Commercial Court (SICC) in Gate Gourmet Korea Co. Ltd. and others v
What is the Basis for the Validation Principle in International Arbitration?
The validation principle has been framed in both positive and negative terms. The former seeks to impute an implied choice of law that would validate the arbitration agreement while the latter operates to negate an implied choice of law that