Skip to main content

Clifford Chance

Clifford Chance


Universal Succession in Singapore – Getting the Recognition It Deserves

13 February 2017

The doctrine of universal succession has finally received judicial recognition in Singapore, almost 60 years after the leading English case on the subject was

The doctrine of universal succession has, for the first time, been considered – and approved – by the Singapore courts in JX Holdings Inc and another v Singapore Airlines Ltd [2016] SGHC 212 (JX Holdings). Prior to this judgment, practitioners in Singapore placed reliance on the English position in concluding that the Singapore courts are likely to follow English common law principles when examining the doctrine of universal succession.

The JX Holdings judgment now puts this beyond doubt and suggests that the Singapore courts may be prepared to recognise succession even (i) where it may not be recognised under English law and (ii) where the succession is not "universal".

Download PDF