[2002] SGHC 196

“A detailed recital of the facts is necessary because forum non conveniens is determined with respect to the particular issues that are likely to be in dispute (Yeoh Poh San & Anor v Won Siok Wan [2002] SGHC 196 at [18]).”

“tibility of the dispute to a transfer. Just as it is sufficient for the court at this stage to form a prima facie view of the governing law of the dispute (see Yeoh Poh San and another v Won Siok Wan [2002] SGHC 196 at [15]), so it suffices for it to make a prima facie determination as to whether a transfer to the SICC”

“n the parties will generally carry little weight (JIO Minerals at [41]; Perwira Habib Bank Malaysia Bhd v Soon Peng Yam and others [1994] 3 SLR(R) 768 at [21]; Yeoh Poh San and another v Won Siok Wan [2002] SGHC 196 at [18]).”

“efore all the evidence is taken, I am entitled to decide the present Summonses based on a prima facie view on the governing law (see the High Court decision of Yeoh Poh San and another v Won Siok Wan [2002] SGHC 196 at [15]). The basic premise behind the governing law as a connecting factor is that it is generally pref”

“in dispute. In a stay application, it is appropriate for the court to form a prima facie view on the governing law, before all the evidence has been heard: see Yeoh Poh San and another v Won Siok Wan [2002] SGHC 196 at [15]. In order to do so, it is first necessary to characterise the issues raised by the claims: see J”