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Reform Of The Choice Of Law Rule Relating To Torts: Report Of The Law Reform Committee Of The Singapore Academy Of Law, Jimmy Yim, Suresh Divyyanathan, Woon Yin Liew, Yock Lin Tan, Joel Tye Beng Lee, Tiong Min Yeo

Research Collection Yong Pung How School Of Law

An act done abroad is actionable as a tort in Singapore if it is both actionable as a tort according to the law of Singapore and the law where the act was done. This double actionability rule which requires actionability by the law of Singapore even though the act in question was done abroad, was first enunciated in the 19th century when proof of foreign law was difficult and unfamiliarity with and perhaps suspicion of foreign law was inevitable. The UK, Australia, and Canada have replaced the rule with a more ‘international’ choice of law rule which reflects changes in …