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Interim injunctions in Restraint of Trade Cases – American Cyanamid or RGA Holdings: a proposed framework

Yixin Edith Chen & Yeo Chuan Tat

[2025] SAL Prac 7

Abstract:
Through a discussion of two High Court decisions issued in 2024 – Shopee Singapore Pte Ltd v Lim Teck Yong [2024] SGHC 29 and MoneySmart Singapore Pte Ltd v Artem Musienko [2024] SGHC 94 – this article examines the framework for granting interim injunctions in restraint of trade cases. It discusses the applicability of, and the relationship between, the American Cyanamid test and the RGA Holdings test in the court’s determination of whether to grant such injunctions. This article further highlights the divergence in the two High Court decisions and sets out a proposed approach for future cases.