Warnings for a new Beginning: Singapore Choice of Law in Tort
To complete our round-up of newly available articles today, we have an article on “Warnings for a New Beginning” by William Tong (University of Nottingham), which explores the tort choice of law rules in Singapore, and how they compare with other common law jurisdictions such as the UK. Here’s the abstract:
In striking contrast with some of the Commonwealth developments in the area of tort choice of law, where notably even the United Kingdom has abandoned the English common law position in relation to tort choice of law for a statutory regime embodied by Part III of the Private International (Miscellaneous Provisions) Act 1995, Singapore has largely maintained its adherence to the English common law position with the unequivocal acceptance by the Singapore Court of Appeal that the “applicable choice of law rule in Singapore with respect to torts committed overseas is that laid down in Phillips v. Eyre” and that the “exception to the rule as formulated in Boys v. Chaplin, Johnson v. Coventry Churchill and Red Sea Insurance” is part of Singapore law as well.
Available to download from here.