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Abstract: This article discusses, in the context of the Singapore International Commercial Court (SICC), issues relating to the recognition and enforcement of judgments. The focus is on three areas. First, the article examines the enforceability of SICC’s fi nal judgments. The utility of hybrid dispute resolution clauses is discussed in light of the innovative Practice Direction No 2 of the Dubai International Financial Centre (DIFC) Courts. Second, the article examines diffi culties in the enforcement of worldwide freezing orders made by the SICC and suggests that there may be no easy solution to the cross-border enforcement of such orders. A similar conundrum is faced by the SICC on the fi nal issue considered, the recognition and enforcement of interlocutory or fi nal judgments made by the SICC against third parties. The author suggests in conclusion that the best solutions to the problems explored may lie in exploring synergies between different modes of dispute resolution.
Keywords: international arbitration; enforcement of judgment; Mareva injunction; international dispute resolution; international commercial court, Singapore International Commercial Court; Dubai International Financial Centre Courts
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