Established in 2015 as a trusted neutral forum to meet increasing demand for effective transnational dispute resolution, the Singapore International Commercial Court (the “SICC”) is a division of the General Division of the High Court and part of the Supreme Court of Singapore. On January 18, 2024, the SICC handed down its first insolvency-related ruling. In Re PT Garuda Indonesia (Persero) Tbk [2024] SGHC(I) (“PT Garuda”), the SICC granted recognition in Singapore of an Indonesian debtor-airline’s “suspension of payments” proceeding under Singapore’s version of the UNCITRAL Model Law on Cross-Border Insolvency (the “Model Law”). The SICC also recognized and enforced the terms of a composition plan approved by creditors and confirmed by an Indonesian court. In so ruling, the SICC overruled objections to recognition interposed by disgruntled aircraft lessors asserting, among other things, that recognition of the Indonesian proceeding would violate Singapore’s public policy because creditors were treated unfairly in the debtor’s composition plan.
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