‘Salami-slicing’ and Issue Estoppel: Foreign Decisions on the Governing Law
One of the requirements for issue estoppel is identity of issue. However, the process of ‘refining down’ or ‘salami-slicing’
Adeline Chong joined SMU in November 2007. She was formerly a lecturer at the School of Law, University of Nottingham. She obtained First Class Honours from the University of Birmingham and subsequently was awarded a scholarship to pursue a Ph.D in Nottingham. The thesis looked at the choice of law issues concerning establishing the voidness of a contract and the restitutionary aftermath of voidness. She has published in leading peer-reviewed journals such as the Law Quarterly Review, International and Comparative Law Quarterly, Lloyd’s Maritime and Commercial Law Quarterly and the Journal of Private International Law. She is the co-author of Hill and Chong, International Commercial Disputes: Commercial Conflict of Laws in English Courts (Oxford, Hart, 4th edn, 2010). She is the Project Lead of the Asian Business Law Institute’s project on the Recognition and Enforcement of Foreign Judgments in Asia. Her work has been cited by the Singapore, Hong Kong, New South Wales and New Zealand Court of Appeals, the Singapore and New Zealand High Courts, the UK Law Commission, as well as in leading texts on conflict of laws such as Dicey, Morris and Collins on the Conflict of Laws (15th edition, 2012). She has also been invited to present papers by the British Association of Canadian Studies, British Institute of International and Comparative Law, Kyushu University and the University of Sydney. She has conducted courses for the Attorney-General Chambers of Malaysia and delivered Continuing Professional Development Talks for Singapore’s Attorney-General Chamber’s Academy and the Law Society of Singapore. She has appeared as an expert on Singapore law before a Finnish court and issued a declaration on Singapore law for a US class action. She was awarded the 2013 School of Law Research Excellence Award and was appointed as a Lee Kong Chian Fellow in 2015. She was a recipient of the School of Law’s Dean’s Teaching Excellence Award in 2016, 2018 and 2020.
One of the requirements for issue estoppel is identity of issue. However, the process of ‘refining down’ or ‘salami-slicing’
The Bahrain International Commercial Court (BICC) was launched on 5 November 2025. It joins the long established Dubai International Financial Centre Courts, Abu Dhabi Global Market Courts and Qatar International Court and Dispute Resolution Centre in the Middle East as a specialist court devoted to resolving international commercial disputes and operating under special procedural rules. […]
By Catherine Shen, Asian Business Law Institute In 2023 Su 05 Xie Wai Ren No. 8 dated March 14, 2025, the Suzhou Intermediate People’s Court of Jiangsu Province in China (Suzhou Court) recognized and enforced civil judgment HC/S194/2022 under file number HC/JUD47/2023 by the Supreme Court of Singapore (Singapore Judgment). The judgment by the Suzhou […]
Written by Yip Man (Professor of Law, Yong Pung How School of Law, Singapore Management University) To bolster Singapore’s position as an international dispute resolution hub, the Singapore International Commercial Court (International Committee) Bill
Written by Catherine Shen, Senior Assistant Director, ABLI Following successful sessions in
By Adeline Chong, Singapore Management University Introduction In two decisions decided within a fortnight of each other, the Singapore Court of Appeal considered anti-suit injunctions pursued to restrain proceedings allegedly brought in breach of arbitration agreements. The first case, Asiana Airlines, Inc v Gate Gourmet Korea Co, Ltd (‘Asiana Airlines’)
The following information has kindly been provided by Anselmo Reyes. The third Asian Private International Law Academy (APILA) Conference will take place in person at Thammasat University in Bangkok, Thailand on Sunday 8 (Day 1) and Monday 9 (Day 2) December 2024. Persons whose abstracts have been selected (see next paragraph) will deliver oral presentations […]
September 2024 Update: List of China’s Cases on Recognition of Foreign Judgments Written by Dr. Meng Yu and Dr. Guodong Du, co-founders of China Justice Observer* On 22 September 2024, China Justice Observer released the 2024 version of the List of China’s Cases on Recognition of Foreign Judgments.
The Yong Pung How Professorship Lecture 2024 will be held on Thursday 23 May 2024 5:00 to 6:30pm Singapore time. Professor Yeo Tiong Min, SC (Hon), who holds the Yong Pung How Chair Professor of Law at Singapore Management University, will be speaking on ‘Past, Present, and Future Tensions: Jurisdiction over Absent Defendants’. The synopsis […]
Application of Singapore’s new rules on service out of jurisdiction: Three Arrows Capital and NW Corp The Rules of Court 2021 (‘ROC 2021’) entered into force on 1 April 2022. Among other things, ROC 2021 reformed the rules on service out of jurisdiction (previously discussed
