SINGAPORE Law and Practice Contributed by: Randolph Khoo, See Chern Yang, Tan Ei Leen and Sharon Ki, Drew & Napier
that procedural requirements for enforcement are met. As long as a tribunal has used every effort to ensure enforceability of the award in places where it could reasonably be expected to be enforced, the tribunal would have met its obligations under Article 41. The court of appeal held that an arbitral tribunal was not expected to predict or guarantee the outcome of any enforcement proceedings with respect to the award it makes. It also held that there is no implied term in every arbitration agreement that any award made shall be in a form that is enforceable in the same manner as a court judgment.
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