In Anupam Mittal v Westbridge Ventures II Investment Holdings, [2023] SGCA 1, the Singapore Court of Appeal (“SGCA”) held that the law governing the arbitration agreement governs.
In Lao Holdings NV v. Government of the Lao People’s Democratic Republic, the SCA followed the principle of minimal judicial intervention at the enforcement stage and affirmed the decision of the SICC to not set aside two investment awards.