14. Grounds on which General Division of High Court must refuse to recognise or enforce foreign judgment

The General Division of the High Court must refuse to recognise or enforce a foreign judgment, or must set aside an order (made pursuant to an application under section 13(1)) that recognises or enforces a foreign judgment, in any of the following circumstances, or in any other circumstances that the Minister may prescribe by regulations made under section 22:

the defendant in the proceedings in which the foreign judgment was obtained was not notified of the document by which the proceedings were instituted or an equivalent document, including the essential elements of the claim, in sufficient time to enable the defendant to defend the proceedings, unless —

the law of the State of origin allows the notification to be challenged; and

the defendant had entered an appearance and presented the defendant’s case without challenging the notification in the court of origin;

the foreign judgment was obtained by fraud in connection with a matter of procedure;

the recognition or enforcement of the foreign judgment would be manifestly incompatible with the public policy of Singapore, including circumstances where specific proceedings leading to the judgment would be incompatible with fundamental principles of procedural fairness in Singapore.