Abstract:
This article critically examines the doctrine of subject matter jurisdiction in Singapore’s conflict of laws, tracing its origins to the seminal Court of Appeal judgment in Burgundy Global Exploration Corp v Transocean Offshore International Ventures Ltd [2014] 3 SLR 381. It identifies three persistent misunderstandings and advocates for a unified doctrine grounded in conflicts and substantive justice, rather than international comity. The analysis demonstrates that subject-matter jurisdiction is a doctrinal gatekeeper that cuts across and (re)shapes multiple conflicts rules. The article concludes that the doctrine’s rigorous application is vital in preserving the coherence of Singapore law in an era of ever-increasing transnational complexity.