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Comparative and Foreign Law

Research Collection Yong Pung How School Of Law

2020

Articles 1 - 4 of 4

Full-Text Articles in Law

Fraud And Foreign Judgments Under Singapore Law, Adeline Chong Oct 2020

Fraud And Foreign Judgments Under Singapore Law, Adeline Chong

Research Collection Yong Pung How School Of Law

A foreign judgment is generally not to be reviewed on the merits at the recognition and enforcement stage. Yet, an exception has always been carved out for fraud under the common law rules on the basis that ‘fraud unravels everything’ (Lazarus Estates Ltd v Beasley [1956] 1 QB 702, 712 per Lord Denning). Thus, English courts allow a judgment debtor to raise fraud at the recognition and enforcement stage even if no new evidence is adduced and fraud had been considered and dismissed by the court of origin (Abouloff v Oppenheimer & Co (1882) 10 QBD 295). This seeming anomaly …


Soft Launch Of The Asian Principles For The Recognition And Enforcement Of Foreign Judgments, Adeline Chong Jul 2020

Soft Launch Of The Asian Principles For The Recognition And Enforcement Of Foreign Judgments, Adeline Chong

Research Collection Yong Pung How School Of Law

In January 2018, we reported on the Recognition and Enforcement of Foreign Judgments in Asia, a publication by the Asian Business Law Institute (ABLI).


The Development Of Singapore Law: A Bicentennial Retrospective, Andrew Phang, Yihan Goh, Jerrold Soh May 2020

The Development Of Singapore Law: A Bicentennial Retrospective, Andrew Phang, Yihan Goh, Jerrold Soh

Research Collection Yong Pung How School Of Law

The present article reviews (in broad brushstrokes) the status of Singapore law during its bicentennial year. It is not only about origins but also about growth – in particular, the autochthonous or indigenous growth of the Singapore legal system (particularly since the independence of Singapore as a nation state on 9 August 1965). The analysis of this growth is divided into quantitative as well as qualitative parts. In particular, the former constitutes an empirical analysis which attempts – for the very first time − to tell the development of Singapore law through numbers, building on emerging techniques in data visualisation …


Diversity Of Shareholder Stewardship In Asia: Faux Convergence, Gen Goto, Alan K. Koh, Dan W. Puchniak May 2020

Diversity Of Shareholder Stewardship In Asia: Faux Convergence, Gen Goto, Alan K. Koh, Dan W. Puchniak

Research Collection Yong Pung How School Of Law

Since the UK adopted the world's first stewardship code in 2010, stewardship codes have proliferated across Asia. Given the UK Code's prominence, it is tempting to assume that every other stewardship code performs the same function as the UK Code. This assumption belies the truth: all these codes--regardless of whether they have in fact drawn inspiration from the UK Code--have taken different trajectories due to each adopting its jurisdiction's distinctive institutional and legal context.Using empirical evidence and in-depth case studies of stewardship in Japan and Singapore, this Article reveals how any reception of United Kingdom-style stewardship concepts is only skin …