Commercial conflict of laws is a significant area of legal scholarship and practice. The chief aim of the course is to examine the foundational principles of commercial conflict of laws in Singapore. First, the course identifies and assesses the set of rules based on which Singapore courts decide whether to entertain international commercial disputes. Second, the course outlines the provisions based on which Singapore courts determine the law governing the parties’ cross-border disputes. Finally, the course outlines the rules according to which courts in Singapore give effect to foreign judgments.

Associate Professor Ardavan Arzandeh 

Not open to anyone who has done:
LL4030V/LL5030V/LL6030V/LLJ5030V; LL4030 / LL5030 /
LL6030 / LLJ5030V International Commercial Litigation;

LL4049V/LL5049V/LL6049V/LLJ5049V;
LL4049/LL5049/LL6049/LL5049 Principles of Conflict of Laws;

LL4205V/LL5205V/LL6205V/ LLJ5205V; LL4205/LL5205/
LL6205/LLJ5205 Maritime Conflict of Laws;

LL4382V/LL5382V/LL6382V/LLJ5382V; LL4382/LL5382/
LL6382/LLJ5382 Private International Law

LL4454/LL5454/LL6454/LLJ5454 Commercial Conflict of Laws at NUS Law, or a substantially similar course elsewhere

This course considers the way that international adjudicators approach fact-finding and factual determinations. The course analyses essential policy questions as to the way legal systems should deal with evidence; considers comparative law perspectives; and aims to integrate these perspectives with practical consideration of the way documents and witnesses are dealt with in international arbitration.

There is no greater divergence between legal families than that pertaining to the treatment of evidence. For international adjudication to meet the needs of participants from all legal families, a proper understanding of comparative approaches and the degree of convergence, is essential to arbitrators and practitioners.

The teaching style involves interactive problem-based learning throughout. Students learn to work with primary materials and will engage in practical simulations in most classes. There is not a heavy workload outside of class time.

LL4339V/LL5339V/LL6339V Comparative Evidence in International Arbitration

The course will cover the following issues:

• Who are the parties to the contract(s) or to the arbitration clause(s) contained therein? The theories applied by courts and arbitral tribunals.
• The extension of the arbitration clause to non-signatories: individuals, states or other companies of the group.
• The possibility of bringing together in one single proceeding all the parties who have participated in the performance of one economic transaction through interrelated contracts.
• Joinder of parties and joinder of claims: voluntary and compelled intervention of third parties, cross-claims and consolidation.
• Appointment of arbitrators in multiparty arbitration cases.
• Specific issues relating to the enforcement of an award in multiparty, multicontract cases.
• The res judicata effect of an award rendered in a connected arbitration arising from the same project.

Saturday, 21 February 2026: 1.00pm to 4.00pm
Sunday, 22 February 2026: 1.00pm to 5.00pm
Monday, 23 February 2026: 1.00pm to 5.00pm)
Tuesday, 24 February 2026: 1.00pm to 5.00pm); 
Wednesday, 25 Febraury 2026: 10.00am to 1.00pm

This course will focus in detail on the instances in which resort to conflict of laws is necessary in the international arbitration context. The objective of this course is to allow participants to realise on how many occasions both State courts and arbitrators will need to apply a conflict of laws analysis despite the claim that conflict of laws issues are not relevant in the international commercial arbitration context. Participants will first be taught to identify what conflict of laws rules may apply and will then be given hypothetical cases and will be asked to critically examine whether a solution can be found that does not require a conflict of laws approach.

NUS Compulsory Core Law Curriculum or common law equivalent.

LL4029V/LL5029V/LL6029V/LC5262V International Commercial Arbitration.

This course will focus on the current challenges faced by investment arbitration at the global level. It will adopt a three-step approach. Students will first acquire an in-depth understanding of the history and functioning of the existing system. On this basis, the different criticisms and reform proposals will be scrutinized. Finally, students will be invited to make their own informed assessment of the existing system, to discuss its evolution and debate possible improvements. The course will be diversified, as it will address both legal and extra-legal issues. Seminars will be interactive and students will be encouraged to participate actively.

Wednesday, 25 February 2026: 2.00pm - 5.00pm
Thursday, 26 February 2026: 10.00am - 2.00pm
Friday, 27 February 2026: 10.00am - 2.00pm
Saturday, 28 February 2026: 10.00am - 2.00pm
Sunday, 1 March 2026: 10.00am - 1.00pm

25 February 2026 - 1 March 2026

This course introduces international arbitration's role in resolving energy disputes. Seminars will address both commercial and investment arbitration. The substantive content of national and international energy laws will be discussed together with the procedural specificities of energy disputes. The course will explore the political aspects of energy disputes, both domestic (resource sovereignty) and international (inter-state boundary disputes).

Participants will study the recent debates on the role of international arbitration vis-à-vis climate change and sustainable development.

The course incorporates practical exercises that will help participants interested in a career in international arbitration and public international law.

International investment law is currently the most prominent, dynamic, and profiled branch of international law. The protection of foreign investment is multifaceted, and is governed by contract law and international law. This course covers the foundations of international investment law, as well as its transmission and entrenchment through arbitration. It equips students with the necessary and cutting-edge knowledge of a highly specialised field.

This course aims to set out the practical realities of dispute resolution in Asia and aims to make students step into the shoes of lawyers and understand how to tackle and strategize real disputes. The course covers topics related to jurisdiction, interim relief, defence and guerrilla tactics, issue estoppel, choice of remedies and dealing with a State in relation to investment treaty disputes to give students a real life understanding of the issues which arise in international disputes. In the context of the substantive issues, the students would also go through facets of the New York Convention and a comparative analysis of the laws of Singapore, England & Wales, India and Hong Kong.

The phenomenon of globalization over the last 50 years has been fuelled not just by technological innovation but also legal innovation. However, in 2016, the vote for Brexit in the UK and the election of Mr Donald Trump as the US President, has challenged the movement towards economic integration. Indeed, one of President Trump's first Executive Orders was to cancel the Trans Pacific Partnership Agreement (TPP) that the previous Obama Administration had worked on for 5 years. With the recent re-election of Mr Trump it is likely that there will be an even greater pushback on globalisation and multilateral trade. It may therefore be more important than ever before to understand and appreciate the existing rules so as to promote the rule of law in what may be an increasingly protectionist environment.

The General Agreement on Tariffs and Trade (GATT) and its successor institution, the World Trade Organization (WTO) have attempted to create a system where the rules for the trade in goods and services are clearer and fairer. The legal innovations found in the GATT and subsequent WTO Agreements have also influenced Free Trade Agreements (FTAs) like the TPP and even International Investment Agreements (IIAs). Even if the Trump Administration hobbles the WTO, the same textual rules will continue to exist in FTAs and IIAs and therefore will need to be understood and applied.

Fundamental to the WTO disciplines is the principle of non-discrimination. The problem often is, however, what constitutes discrimination, whether such discrimination can be justified and whether non-economic factors such as health and the environment or other public policy considerations can modify the rules. This tension in World Trade Law is a theme in both the disciplines for trade in goods and services as well as the agreements on standards like the TBT and SPS as well as even the trade remedies rules such as Safeguards, Subsidies and Anti-Dumping.