On 22 October 2012, in Astro Nusantara International BV and others v PT Ayunda Prima Mitra and others [2012] SGHC 212, the Singapore High Court rejected attempts to resist the enforcement of SIAC awards on grounds of lack of jurisdiction, where those grounds were raised only after the expiry of the time limit for challenges to the awards. It was not possible to raise such jurisdictional objections for the first time at the recognition or enforcement stage.

The judgment includes interesting discussion of the relationship between the UNCITRAL Model Law and the Singapore International Arbitration Act, and suggests that jurisprudence from civil law countries that have adopted the Model Law is likely to be more influential in the Singapore courts than caselaw from common law jurisdictions such as the UK.

We will provide a full analysis of this judgment shortly.