Wan Sern Metal Industries Pte Ltd v Hua Tian Engineering Pte Ltd [2025] SGCA 5

The Singapore Court of Appeal (“SGCA“) in Wan Sern Metal Industries Pte Ltd v Hua Tian Engineering Pte Ltd [2025] SGCA 5 highlighted the important role of pleadings in a documents-only arbitration and their role in ensuring that all parties have a reasonable opportunity to respond to their counterparty’s case. When unpleaded issues in a documents-only arbitration are raised, tribunals should clarify the parties’ positions on the unpleaded issues and direct an amendment of the pleadings if appropriate.

 

This is an uncommon case where the SGCA decided to set aside an award on the basis that the principles of natural justice were breached in an documents-only arbitration. Our case update sets out a summary of the case and provides some practical takeaways to parties, counsel and arbitrators involved in documents-only arbitrations.

 

If you would like to know more about this area of law, please reach out to our Directors, Jiaxiang Zhuo (Head of International Arbitration) and Colin Liew (Head of International Litigation). The Court’s decision may be accessed here, and our case update can be accessed here.