This paper sets out the facts and key points from sets out the facts and key points from the High Court and Court of Appeal’s decisions on the “Jeil Crystal”. It considers how The Jeil Crystal interfaces with the ROC 2021. Specifically, it is argued that the Singapore courts are now empowered to substantively vary their orders under the ROC 2021. The second part of this comment focuses on developing a system for exercising this power by drawing on the UK Civil Procedure Rules and the related jurisprudence. The third part of the comment offers a brief survey of the position in three other commonwealth jurisdictions—Hong Kong, Canada, and Australia—so that readers may appreciate how approaches to the same legal problem have converged (or diverged).

Acknowledgements
This research paper has been made possible by the funding support from the Singapore Maritime Institute (SMI) Project ID SMI-2022-ET-03.