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Enforcement of foreign awards: excess of powers and public policy

Arbitration Law Monthly

Enforcement of foreign awards: excess of powers and public policy

In Quanzhou Sanhong Trading Ltd Liability Co Ltd v ADM Asia-Pacific Trading Pte Ltd [2017] SGHC 199 it was argued before Chua Lee Ming J that the Singapore courts ought to refuse to enforce a foreign award under the New York Convention because the tribunal had erred in ruling that the substantive contract was governed by Chinese law rather than English law. The court found that an error of that type was no basis for refusing enforcement.

Qaunzhou : the facts

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