Abstract:
The recent House of Lords decision of In re HIH Casualty and General Insurance Ltd and the opinion by the Privy Council in Cambridge Gas v Navigator Holdings can be seen as significant steps towards greater collaboration between courts in the context of cross-border insolvencies, although it will be argued the former more so than the latter. This note critically analyses the decisions, including through a somewhat traditional common law conflict of laws perspective. Our local court also has not too long ago showed signs favourable to universalism in insolvency administration, and it remains to be seen how Singapore case law will react to these developments, hopefully with the aid of some legislative amendments.