Entries by Saloni Khanderia

Can a Seat Court Injunct a Foreign Non-Party to an Arbitration? Singapore High Court clarifies in Alphard Maritime v Samson Maritime (2025) SGHC 154

/in /by

This guest post is posted on behalf of Kamakshi Puri, Senior Associate at Cyril Amarchand Mangaldas, Delhi, India, and dual-qualified lawyer (India and England and Wales).   The Singapore High Court recently clarified the scope of the court’s jurisdiction over foreign non-parties to the arbitration. In an application to set aside two interim injunctions, in Alphard […]

Charuvila Philippose v. P.V. Sivadasan: Harmonizing India’s Civil Procedure Code and the Hague Service Convention

/in /by

Written by George Jacob, Incoming Associate, Bombay Law Chambers Globalisation has led to a rise in cross-border disputes, making international service of summons increasingly relevant. While domestic service in India is straightforward, sending summons to foreign defendants involves complex legal procedures. Proper service ensures that the defendant is duly notified and can respond, embodying the […]

Enforceability Denied! When the SICC’s Authority Stopped at India’s Gate

/3 Comments/in , /by

Written by Tarasha Gupta, BALLB (Hons), Jindal Global Law School, and Saloni Khanderia, Professor, Jindal Global Law School (India)   The Singapore International Commercial Court (“SICC”) has become a preferred hub for hearing litigation and arbitration of international commercial disputes. Accordingly, many decisions from the SICC require recognition and enforcement in India. In this light, […]

Sovereign Immunity and the Enforcement of Investor–State Arbitration Awards: Lessons from Devas V. India in Australia, The United Kingdom and India

/in /by

Written by Samhith Malladi, Dual-qualified lawyer (India and England & Wales), and Senior Associate, Shardul Amarchand Mangaldas [Bombay office]; and Niyati Gandhi, Partner, Dispute Resolution, Shardul Amarchand Mangaldas [Bombay office]   The Recalibration of Enforcement Doctrine The global campaign to enforce arbitral awards against the Republic of India arising from its long-running dispute with Devas […]

A New Precedent in Contract Conflicts: Decoding the Tyson v. GIC Ruling on Hierarchy Clauses

/in /by

By Ryan Joseph, final-year BBA LLB (Hons) student, Jindal Global Law School, India. Introduction The recent decision of the UK High Court (“Court”) in Tyson International Company Limited (“Tyson”) v. General Insurance Corporation of India (“GIC”) sets a critical precedent for cases that lie at the intersection of arbitration, contractual hierarchy, and judicial intervention through […]

Defending Access to Justice: The Crucial Battle for the IJI

/1 Comment/in /by

Published on behalf of the IJI, Den Haag In the heart of The Hague, a critical institution of international legal knowledge faces an existential threat. The International Juridical Institute (IJI) (translated in English to mean the Hague Institute for Private International Law), a venerable organization with a century-long history of providing essential legal guidance, stands […]

Exploring the Inference of Similarity in Foreign Law

/in /by

Hot off the press and published in the Cambridge Law Journal, the article “The Inference of Similarity,” written by Marcus Teo, delves into the intricacies of what has traditionally been referred to as the “presumption of similarity” in English legal proceedings. Teo’s work challenges the conventional understanding of this presumption, arguing that it should be […]

Going International: The SICC in Frontier Holdings

/2 Comments/in /by

By Sanjitha Ravi, Jindal Global Law School, OP Jindal Global University, Sonipat, India The Singapore International Commercial Court (“SICC”) in Frontier Holdings Ltd v. Petroleum Exploration (Pvt) Ltd overturned a jurisdictional ruling by an International Chamber of Commerce (“ICC”) arbitral tribunal, holding that the tribunal did, in fact, have jurisdiction to hear the dispute. The […]