Choice of Court Agreements Act 2016 · 2020 Revised Edition · Part 3 · Recognition and Enforcement of Foreign Judgments and Enforcement of Judicial Settlements
16. Refusal of recognition or enforcement of foreign judgment awarding non-compensatory damages
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The General Division of the High Court may refuse to recognise or enforce a foreign judgment, or may set aside an order (made pursuant to an application under section 13(1)) that recognises or enforces a foreign judgment, if, and to the extent that, the foreign judgment awards damages (including exemplary or punitive damages) in excess of compensation for the actual loss or harm suffered by the party awarded the damages.
foreign judgment
“foreign judgment” means a judgment given by a court of a Contracting State (other than Singapore), being —(a)a chosen court; or(b)a court to which a chosen court has transferred, in accordance with the law or practice relating to the allocation of jurisdiction or transfer of cases among courts in that Contracting State, the case to which the judgment relates;
In making its decision under subsection (1), the General Division of the High Court must take into account whether, and the extent to which, the damages awarded by the court of origin serve to cover costs and expenses relating to the proceedings in which the foreign judgment was obtained.
court of origin
“court of origin”, in relation to a foreign judgment for which recognition or enforcement is sought under this Act, means the court that has given the foreign judgment;