There are not many judicial decisions which, before their release, can be said to be highly anticipated by the international commercial arbitration community. The Singapore Court of Appeal’s decision in PT First Media (formerly known as PT Broadband Multimedia TBK) v Astro Nusantara International BV and others and another appeal (“Astro”)1 is undoubtedly one of those. The decision has spawned more than a handful of updates and commentaries. As one would expect from any highly anticipated decision, not everyone seems to agree with the outcome. Fortunately or unfortunately, Astro has and will continue to generate much debate in many other areas in international commercial arbitration, much as Dallah Real Estate and Tourism Holding Co v Ministry of Religious Affairs of the Government of Pakistan 2 (“Dallah”) did.