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SICC reaffirms exclusive setting aside power of seat court and grants anti-suit injunction

In Pertamina International Marketing & Distribution Pte Ltd v P-H-O-E-N-I-X Petroleum Philippines, Inc [2024] SGHC(I) 13 , the Singapore International Commercial Court (SICC) dismissed the respondent's application to discharge an anti-suit injunction that had been previously granted by the SICC. This injunction was against court proceedings in the Philippines, which were essentially an attempt to invalidate a Singapore-seated award.

The SICC affirmed that actions to invalidate an award outside its seat violate the fundamental principle of arbitration law, which states that only the courts of the seat have the authority to set aside any award rendered there. The SICC has original jurisdiction to grant post-award injunctions and related declarations, ordering the discontinuance of foreign proceedings initiated in breach of arbitration clauses that designate the Singapore Courts as the exclusive supervisory court, even for cases commenced in the SICC.

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