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[From Singapore Office] Reciprocal Enforcement of Foreign Judgments in Singapore: Recent Reforms

NO&T Dispute Resolution Update

NO&T Asia Legal Review

Claire Chong
Nagashima Ohno & Tsunematsu
Journal /
NO&T Dispute Resolution Update No.2/NO&T Asia Legal Review No.59 (April, 2023)

A PDF file of the bilingual version is also available by clicking on “Download full text (PDF)”. For details on our Dispute Resolution Team at the Singapore Office, please refer to this PDF file.

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*Please note that this newsletter is for informational purposes only and does not constitute legal advice. In addition, it is based on information as of its date of publication and does not reflect information after such date. In particular, please also note that preliminary reports in this newsletter may differ from current interpretations and practice depending on the nature of the report.


Singapore has recently introduced reforms to its statutory framework for the recognition and enforcement of foreign court judgments.

In general, foreign court judgments may be enforced in Singapore (i) through a common law action for the judgment debt or (ii) by registration under statute. With effect from 1 March 2023, a single regime under the Reciprocal Enforcement of Foreign Judgments Act (“REFJA”) will govern the registration of foreign judgments in civil proceedings.

The new framework marks an important step in expanding the scope of judgments covered under the REFJA. It also positions Singapore to negotiate further reciprocal enforcement agreements on a country-by-country basis. As the REFJA regime continues to develop, litigants can expect to realise a wider range of civil remedies obtained from foreign courts.

Key reforms to the REFJA

Consolidation of statutory framework

The reforms comprise the repeal of the Reciprocal Enforcement of Commonwealth Judgments Act 1921 (“RECJA”) and consequential amendments to the REFJA. With the repeal of the RECJA, the statutory framework for reciprocal enforcement of judgments is now consolidated into a single regime under the REFJA. This is intended to streamline the process and improve efficiency for litigants seeking to enforce foreign court judgments in Singapore.

Recognised jurisdictions

The REFJA currently applies to the following jurisdictions, the majority of which were transferred from the RECJA:

  • Australia
  • Brunei Darussalam
  • India
  • Hong Kong SAR
  • Malaysia
  • New Zealand
  • Pakistan
  • Papua New Guinea
  • Sri Lanka
  • United Kingdom of Great Britain and Northern Ireland

Details of the reciprocal arrangements for enforcement between Singapore and each of the above listed jurisdictions (such as recognised courts and types of registrable judgments) are set out in two orders:

  • the Reciprocal Enforcement of Foreign Judgments (Hong Kong Special Administrative Region of the People’s Republic of China) Order 2001; and
  • the Reciprocal Enforcement of Foreign Judgments (United Kingdom and The Commonwealth) Order 2023.

A judgment registered under the REFJA would, for the purposes of enforcement, have the same force and effect of a judgment issued by the Singapore courts.

The REFJA may, with time, be expanded to include reciprocal enforcement agreements or arrangements with other countries. These would be negotiated and agreed with each country on an individual basis. Likely factors to be considered include: the extent to which the court systems of Singapore and that of the foreign country are compatible, the needs of litigants and the respective interests of the countries’ considered.

Covered judgments

Prior to the reforms, only final money judgments from superior courts of recognised jurisdictions could be enforced by registration. The REFJA has now been expand in scope to include an additional four types of judgments issued in civil proceedings:

  • non-money judgments;
  • lower court judgments;
  • interlocutory judgments; and
  • judicial settlements, consent judgments, consent orders.

These developments are significant in at least the following ways.

  • Non-monetary relief, such as injunctions (such as freezing orders or those requiring a party to refrain from an act) and orders for specific performance, are often important ways to protect a litigant’s rights. Interlocutory orders can similarly be effective in preserving the effectiveness of a final judgement to be entered. Such orders can now be registered under the REFJA if the court considers that such enforcement would be just and convenient.
  • The recognition of judgments issued by more tiers within recognised courts also allows litigants increased access to the fruits of litigation commenced outside Singapore.
  • Parties may reach a settlement without pursuing the litigation process to its end. In these instances, settlement arrangements concluded before a court may be recorded as consent judgments or orders. The recognition of judicial settlements, consent judgments and orders helps ensure finality to the parties’ disputes and gives effect to the binding and conclusive nature of agreed settlements.

As the REFJA regime is founded on the principle of reciprocity, the Act sets out certain circumstances in which foreign judgments that will not be recognised. For example, the following judgments would not be recognised:

  • a judgment given by a recognised court on appeal from a non-recognised court;
  • a judgment or other instrument that is regarded for the purposes of its enforcement as a judgment of a recognised court but that was given or made in another foreign country; and
  • a judgment given by a recognised court in proceedings founded on a judgment of a court in another foreign country and having as their object the enforcement of the second mentioned judgment.
  • The regime under the REFJA does not apply to foreign judgments which may be recognised or enforced in Singapore under the Choice of Court Agreements Act, which implements the Hague Convention on Choice of Court Agreements.

Implications for Japanese litigants

As Singapore does not have an existing reciprocal enforcement agreement or arrangement with Japan, a money judgment issued by the courts of Japan may be enforced in Singapore by commencing a fresh action for the amount due under it. This will be subject to common law requirements being met (such as the judgment being for a definite sum of money, final and conclusive as between the same parties).

Litigants from Japan who obtain covered judgments from current recognised jurisdictions under the REFJA as set out above may, however, apply for enforcement by registration under the REFJA.


Singapore continues to position itself as a choice center for international dispute resolution and settlement, including through regular review and improvements to its legal infrastructure. The new REFJA regime will in practical terms enable litigants to enforce a wider range of judgments granted by foreign courts, including important non-monetary and interlocutory remedies.

This newsletter is given as general information for reference purposes only and therefore does not constitute our firm’s legal advice. Any opinion stated in this newsletter is a personal view of the author(s) and not our firm’s official view. For any specific matter or legal issue, please do not rely on this newsletter but make sure to consult a legal adviser. We would be delighted to answer your questions, if any.

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