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Singapore: Litigation
This country-specific Q&A provides an overview of Litigation laws and regulations applicable in Singapore.
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What are the main methods of resolving commercial disputes?
The three main methods in Singapore for resolving disputes are litigation, arbitration, and mediation.
Litigation is the primary method of resolving commercial disputes in Singapore. Civil proceedings may be commenced in either the Supreme Court or the State Courts, depending on the quantum of the claims. Litigants with a transnational commercial dispute may also seek recourse though the ("SICC"), which is part of the Supreme Court of Singapore.
Arbitration in Singapore is governed by the Arbitration Act (for domestic arbitration) and International Arbitration Act (for international arbitration). Singapore is also party to the New York Convention. In recent years, the Singapore International Arbitration Centre ("SIAC") has grown to become one of the most widely used arbitration centres in the Asia-Pacific region and the world.
Parties seeking a consensual resolution may choose mediation. In Singapore, mediation is also supported by various public and private institutions in Singapore, such as the Singapore Mediation Centre, the Singapore International Mediation Centre, and the State Courts. Singapore also hosted the Singapore Convention on Mediation in 2019.
What are the main procedural rules governing commercial litigation?
The main procedural rules governing commercial litigation are the Rules of Court ("ROC"). The ROC govern not just the procedural aspects of litigation but also some substantive aspects such as when a party must provide particulars of pleadings or specific discovery. The ROC are supplemented by the Supreme Court Practice Directions and the State Courts Practice Directions, which provide further practical guidance on the rules for counsel and litigants.
It bears noting that new ROC have been proposed and are expected to come into effect in the fourth quarter of 2021. The new ROC are the product of recommendations by the Civil Justice Commission constituted by the Chief Justice in 2015 to modernise the litigation process, enhance the efficiency and speed of adjudication, and maintain costs at reasonable levels.
What is the structure and organisation of local courts dealing with commercial claims? What is the final court of appeal?
The Supreme Court comprises the High Court and the Court of Appeal. The SICC is also part of the Supreme Court. The State Courts comprise the District Courts, Magistrates' Courts, Coroners' Courts, Small Claims Tribunals, Community Disputes Resolution Tribunals and Employment Claims Tribunals.
The jurisdiction of each type of Court depends on the quantum or the nature of the claim. In general, only certain categories of claims which do not exceed S$20,000 in quantum may be heard by the Small Claims Tribunals. However, this limit may be increased to S$30,000 if both parties consent in writing.
Commercial claims not exceeding $60,000 in quantum may be heard in the Magistrates' Courts, and civil claims for more than $60,000 but not exceeding $250,000 in quantum may be heard in the District Courts.
Civil claims which exceed $250,000 in quantum are heard by the High Court. The High Court has recently been restructured to comprise a General Division of the High Court ("General Division") and the Appellate Division of the High Court ("Appellate Division"). The SICC is part of the General Division of the High Court.
The General Division of the High Court exercises original and appellate jurisdiction. However, appeals arising from a decision of the General Division in civil matters will be allocated between the Appellate Division and the Court of Appeal in accordance with the statutory framework set out in the Sixth and Seventh Schedules of the Supreme Court of Judicature Act ("SCJA").
The Court of Appeal is the final appellate court in Singapore and may hear appeals arising from the Appellate Division and the General Division. Certain appeals require leave of court before they are allowed to be heard by the Court of Appeal.
How long does it typically take from commencing proceedings to get to trial?
This substantially depends on the number of interlocutory applications taken out at the pre-trial stage. Nevertheless, Pre-Trial Conferences ("PTCs") expedite proceedings commenced in the Singapore courts, as part of a proactive case management system. This allows the court to monitor the progress of cases and make the necessary directions to facilitate the progress of a case to trial.
The ROC contain various procedures for claims such as the filing of summary judgment or striking out applications which enable certain clear-cut cases to be decided without the need for a full trial. If such applications are successful, cases can possibly be resolved within a matter of months.
Under the new ROC that are expected to come into effect in the fourth quarter of 2021, parties can expect proceedings to be more streamlined. Parties will have to indicate at an early stage in proceedings which interlocutory applications they intend to file and will have to file them in one single interlocutory application. The court's permission must be obtained to file any further interlocutory applications which were not previously indicated.
Are hearings held in public and are documents filed at court available to the public? Are there any exceptions?
Hearings are generally open to the public, other than PTCs and hearings that take place in Judges' and Registrars' chambers, which are not open to the public. A hearing may also be closed to the public in exceptional circumstances, such as a hearing involving the testimony of a vulnerable witness. Parties involved in international commercial cases before the SICC also apply for the proceedings to be confidential. Applications may also be made for proceedings under the Arbitration Act or International Arbitration Act to be heard otherwise than in open court.
A person may apply to inspect case files and court documents under Order 60 of the ROC. A Request to Inspect has to be filed to court and is subject to the approval of the Registrar and the payment of the applicable fees. It is possible for parties (especially for proceedings under the Arbitration Act and International Arbitration Act) to apply for the court files for their cases to be sealed which will mean that the files cannot be inspected by members of the public.
What, if any, are the relevant limitation periods?
The relevant limitation periods for different kinds of claims are set out in the Limitation Act. For civil claims in contract or tort, the limitation period is 6 years from the date on which the cause of action accrues. Part III of the Limitation Act provides for extension of the limitation periods in certain circumstances.
For civil claims concerning trust property, the limitation period is also 6 years from the date on which the cause of action accrues. However, section 22(1) of the Limitation Act also states that no period of limitation shall apply to an action by a beneficiary if the action relates to any fraud on the part of the trustee, or if the action is brought to recover from the trustee trust property or any proceeds thereof.
Any actions for the enforcement of any judgment have a limitation period of 12 years.
What, if any, are the pre-action conduct requirements in your jurisdiction and what, if any, are the consequences of non-compliance?
For claims heard in the General Division of the High Court, a pre-action conduct protocol has been established specifically for medical negligence cases, with the objectives of enabling an assessment of whether a claimant has a viable cause of action and to facilitate the swift resolution of the dispute. The parties are required to, amongst other things, undergo pre-action discovery of documents, including any expert report(s). The protocol may be found at Appendix J of the Supreme Court Practice Directions.
For claims heard in the State Courts, pre-action conduct requirements apply for the following types of cases: defamation, medical negligence, personal injury claims, non-injury motor accident actions, and business-to-business debt claims. These protocols may be found in the State Court Practice Directions.
In general, non-compliance with pre-action conduct requirements may result in adverse costs orders being made against the party in breach.
How are commercial proceedings commenced? Is service necessary and, if so, is this done by the court (or its agent) or by the parties?
Civil proceedings are commenced by way of either a Writ of Summons or an Originating Summons. Claims which involve substantial disputes of fact are typically commenced by a Writ of Summons. In contrast, claims which do not involve substantial disputes of fact may be commenced by way of Originating Summons.
Regardless of whether the proceedings are commenced by way of a Writ of Summons or Originating Summons, the originating process must be served personally on each defendant by the plaintiff within 6 months from the time the claim is filed if served within the jurisdiction or 12 months if served outside the jurisdiction.
It is necessary to first obtain leave from the court to serve the Writ of Summons or Originating Summons out of Singapore. Order 11 of the ROC sets out the circumstances under which leave of the court may be granted. The plaintiff must satisfy the court that one of the categories under Order 11 is engaged, that the plaintiff has a good cause of action and that there is a real issue to be tried by the court.
Service can be effected by a process server of the court or by the parties.
Under the new ROC that are expected to come into effect in the fourth quarter of 2021, a claimant must commence proceedings by way of an Originating Claim or an Originating Application. A claimant must commence proceedings by an Originating Claim if the material facts are in dispute. In contrast, claims where material facts are not in dispute may be commenced by way of an Originating Application.
An Originating Claim or Originating Application will only be valid for service for an initial period of 3 months from its date of issue. An application may be made to extend the validity of the Originating Claim or Originating Application. However, except in a special case, the court may extend the validity of an Originating Claim or Originating Application only twice, and by not more than 3 months each time.
The class of persons who may effect personal service have been extended under the new ROC.
Under the new ROC, for service out of Singapore, leave of court must still be obtained (except where parties have a Contract allowing for service out of Singapore). However, the plaintiff only has to satisfy the court that it has the jurisdiction or is the appropriate court to hear the action.
How does the court determine whether it has jurisdiction over a claim?
For claims commenced in the Supreme Court, section 16 of the SCJA states that the High Court has jurisdiction to hear any action where the defendant has been duly served with any originating process of a claim in a Singapore court (whether within or outside of Singapore), or if the defendant has submitted to the jurisdiction of the High Court.
Even if a court has jurisdiction, a court may decline to exercise its jurisdiction in certain circumstances, for instance, where it is of the view that Singapore is not the appropriate forum for the dispute to be heard.
How does the court determine what law will apply to the claims?
Claims in contract
In determining which law would govern a claim in contract, the courts will consider the following:
Whether the parties had expressly chosen a system of law to govern the contract. Such choice will be valid if it is bona fide and legal and if there is no reason for avoiding the choice on the ground of public policy.
If there is no express choice of law, whether there is an implied choice of law by the parties. The Singapore court will focus on the parties' intentions that can be objectively ascertained from the terms of the contract and the surrounding circumstances.
If there is no implied choice of law, the Singapore court will consider, on balance, which law has the closest connection with the contract in question and circumstances surrounding the inception of that contract.
Claims in tort
Claims in the Singapore court for torts committed in Singapore are generally recognised as being governed by Singapore law.
For claims for torts committed outside of Singapore, the Singapore court will apply the double actionability rule to determine if Singapore law applies, that is, whether the tort is actionable both under the law of the jurisdiction in which the tort was committed as well as the substantive law of Singapore. This is subject to an exception allowing the Singapore court to apply either Singapore law, the law of the jurisdiction in which the tort was committed, or the law of a third country with the most significant relationship with the tort if injustice or unfairness would otherwise result if the double actionability rule is applied. However, this exception is applied strictly.
In what circumstances, if any, can claims be disposed of without a full trial?
Pursuant to Orders 13 and 19 of the ROC, the plaintiff may enter default judgment against the defendant that fails to enter an appearance or to file a defence within the time stipulated in the ROC. If the claim is for a liquidated sum, the plaintiff may apply for final judgment in default against the defendant. If the claim is for an unliquidated sum, the plaintiff may only enter interlocutory judgment against the defendant for damages to be assessed.
Summary judgment and disposal of case on point of law
Pursuant to Order 14, rule 12 of the ROC, the plaintiff can apply for summary judgment against the defendant on the grounds that the defendant has no real defence to any part of the claim (apart from the quantum of damages). However, the defendant may show cause why summary judgment should not be granted by raising one or more triable issues.
The plaintiff can apply to the court to dispose of the case by determining any question of law or construction of any document. The court will exercise its discretion to do so when such a determination will fully dispose of the entire cause or matter or any claim or issue therein, subject only to any possible appeal.
Judgment on admission of facts
Under Order 27 of the ROC, any party may apply to court for a judgment based on admissions made by the other party, without waiting for the determination of any other question between the parties. The admissions can be taken from the pleadings or by serving a notice on the other party requiring him to admit the facts specified in the notice. The admission sought to be relied on must be a clear admission of all the facts necessary to establish the cause of action.
Striking out
Pursuant to Order 18, rule 19 of the ROC, any party can apply for the court to strike out or amend any pleading on the grounds that: (a) it discloses no reasonable cause of action or defence; (b) it is scandalous, frivolous or vexatious; (c) it may prejudice, embarrass of delay the fair trial of the action; or (d) it is otherwise an abuse of process of the court. The threshold for striking out is high and will generally be granted only when the pleading is legally or factually unsustainable.
What, if any, are the main types of interim remedies available?
The main types of interim remedies are governed by Order 29 of the ROC, examples of which are set out below.
Interim injunctions: The court can grant injunctions pending the outcome of the trial, which apply only until the final determination of the rights of the parties. These include mandatory injunctions, prohibitory injunctions, quia timet injunctions, anti-suit injunctions and Mareva injunctions (domestic and worldwide) to freeze the assets of the defendant.
Interim payment: The court can order a party in a pending proceeding to make interim payments to another party on account of any damages, debt or other sum, excluding costs, which he may subsequently in the proceeding be adjudged to be liable to pay.
Detention, preservation and search orders: The court can order that any property which is the subject matter of the dispute be detained, taken into custody, preserved, or inspected. The court can also order a sample to be taken of the property. In more extreme circumstances, the court can grant a search order (Anton Piller order) permitting a party to enter another's premises to search for and seize property or evidence. Such orders are made to prevent the defendant from removing, destroying or concealing incriminating evidence in his possession.
After a claim has been commenced, what written documents must (or can) the parties submit and what is the usual timetable?
After a claim has been commenced, the parties must file their respective pleadings typically within 14 days of the prior pleading. The plaintiff starts the action by issuing and serving a writ of summons. A statement of claim may be served on the defendant together with the writ of summons, or within 14 days after the defendant has entered an appearance in the action.
The defendant must then serve a defence on the plaintiff within 14 days after the time limited for appearing, or after the service of the statement of claim on him, whichever is the later.
The plaintiff then has 14 days after the service of the defence to serve a reply. The same timelines apply if the defendant has made a counterclaim against the plaintiff along with filing the defence.
Typically, after the close of pleadings, the parties enter the stage of discovery. At this stage, parties are required to disclose documents in their possession, custody or power that are relevant to the case at hand. If any party has reason to believe that the other party has other documents in their possession, custody or power that have not been disclosed, an application for specific discovery may be made to compel the other party to produce the undisclosed documents. The rules on disclosure are covered in more detail below.
In all civil trials in Singapore, the evidence of witnesses is typically given by way of affidavit. Prior to trial, parties would usually be directed to file and exchange the affidavits of evidence-in-chief of all witnesses in accordance with the timelines set by the court.
Finally, at trial, counsel will submit written opening statements and closing submissions containing all legal submissions for their case.
What, if any, are the rules for disclosure of documents? Are there any exceptions (e.g. on grounds of privilege, confidentiality or public interest)?
Each party must disclose documents relevant to the issues arising in the action which are or at any time have been in the party's possession, custody or power. Importantly, these include not only documents that are favourable to that party's case and which he will rely on, but also all documents that could adversely affect that party's case and/or support another party's case. The duty of disclosure continues throughout the proceedings.
A party's failure to comply with his discovery obligations may lead to the court making an order that the action be dismissed, or that the defence be struck out and judgment entered accordingly.
If any party has reason to believe that the other party has other documents in their possession, custody or power that have not been disclosed, an application for specific discovery may be made to compel the other party to produce the undisclosed documents. The court will make an order for specific discovery only if it is necessary for disposing fairly of the matter or for saving costs.
There are two main exceptions to disclosure.
First, documents subject to privilege need not be disclosed. In Singapore, there is both legal advice privilege and litigation privilege, which cover respectively a party's communications with his lawyers for the purpose of obtaining legal advice and any communications or documents sent or created for the dominant purpose of litigation. Documents that are protected by either form of privilege need not be disclosed. If any other party seeks disclosure of an allegedly privileged document, it is for that party to show that the document is not privileged.
Second, if a document is required to be withheld under any law on the ground that its disclosure would be injurious to the public interest, that law would prevail over the rules of disclosure.
Save for the above exceptions, the fact that a document is confidential is not in itself a sufficient ground to refuse disclosure of that document.
How is witness evidence dealt with in commercial litigation (and, in particular, do witnesses give oral and/or written evidence and what, if any, are the rules on cross-examination)? Are depositions permitted?
In Singapore, witnesses usually give written evidence before trial (in the form of affidavits) and oral evidence during the trial (during cross-examination).
Order 38, rule 2 of the ROC requires witnesses to give evidence before the trial or hearing of a matter by way of affidavit. However, if the witness does not attend the trial or hearing for cross-examination when ordered to do so by the court, his affidavit shall not be used as evidence without leave of court. The court also retains the power to order witnesses to attend trial to be examined without giving a prior affidavit of evidence in chief.
Further, during evidence-in-chief at the trial or hearing of any matter, a deponent to an affidavit may not give evidence the substance of which is not contained in his affidavit, except in relation to matters which have arisen after the filing of the affidavit or with leave of court.
The rules on cross-examination are set out in sections 140, 145, 147 and 148 of the Evidence Act. For example, cross-examination must relate to relevant facts but need not be confined to the facts testified to during evidence-in-chief. Leading questions may be asked in cross-examination, subject to the limitations set out in section 145 of the Evidence Act. A witness may be cross-examined as to previous statements made by him in writing and relevant to matters in question in the suit. A witness may also be asked questions which tend to test his accuracy, veracity, or credibility, to discover who he is and his position in life, or to shake his credit by injuring his character.
Under Order 38, rule 9 of the ROC, the court may permit evidence by way of depositions to be received in evidence at trial if (a) the deposition was taken pursuant to an order under Order 39, rule 1 of the ROC; or (b) if the party against whom the evidence is offered consents or it is proved to the court's satisfaction that the deponent is dead, beyond the jurisdiction of the court, or unable to attend trial due to sickness or other infirmity.
Is expert evidence permitted and how is it dealt with? Is the expert appointed by the court or the parties and what duties do they owe?
Expert evidence is permitted in Singapore. The court may appoint independent experts under Order 40 of the ROC, or the parties to an action may engage experts under Order 40A of the ROC.
Under Order 40 of the ROC, an independent court expert may be appointed on the application of any party or by the court on its own motion, to inquire into and report upon any question of fact or opinion not involving questions of law or construction. The question to be submitted to a court-appointed expert and the instructions given to him shall be settled by the court, failing agreement between the parties. Any party may apply for leave to cross-examine the expert on his report within 14 days of receiving a copy of the report.
Under Order 40A, rule 2 of the ROC, an expert appointed by a party has a duty to assist the court on the matters within his expertise. This duty overrides any obligation to the person from whom the expert has received instructions or payment. The expert evidence is to be given in a written report signed by the expert and exhibited in an affidavit testifying that the report is the expert's and he accepts full responsibility for the report. A party may put written questions to an expert instructed by another party about his report, with leave of court.
Can final and interim decisions be appealed? If so, to which court(s) and within what timescale?
Appeals against final and interim decisions made by the Supreme Court
Recent developments in 2021
As of 2 January 2021, the High Court has been restructured into the new (i) General Division and (ii) Appellate Division.
Notably, civil appeals arising from a decision of the General Division are now allocated between the Appellate Division and the Court of Appeal.
The Court of Appeal hears only certain prescribed categories of civil appeals specified in the Sixth Schedule to the SCJA, including cases relating to constitutional / administrative law, contempt of court, arbitration, insolvency, the law of patents, decisions of the SICC, and orders made under the Mediation Act 2017 or the Singapore Convention on Mediation Act 2020.
All other civil appeals arising from a decision of the General Division are heard by the Appellate Division.
Appeals against the decision of a Registrar
Any decision of a Registrar (which would generally pertain to an interlocutory application) may be appealed to a Judge in chambers in the General Division under Order 56, rule 1 of the ROC, subject to certain exceptions under Order 56A, rule 18 and Order 57, rule 16A of the ROC.
Unless otherwise ordered by the court:
the notice of appeal must be issued within 14 days after the decision was made, and the notice of appeal must be served within 7 days of it being issued; and
the commencement of an appeal will not operate as a stay of the proceedings in which the appeal is brought.
Appeals against decisions of the General Division
Decisions of the General Division may be appealed to the Appellate Division under Order 56A of the ROC, or to the Court of Appeal under Order 57 of the ROC.
Section 29A of the SCJA sets out certain matters that are not appealable, or appealable only with the leave of the court. Leave is required to appeal where, for instance, the amount in dispute or value of the subject matter does not exceed $250,000 (subject to the exceptions in the Fifth Schedule to the SCJA), or when leave is otherwise expressly required under written law.
If an application for leave to appeal is required to be made to the General Division under Order 56, rule 3 of the ROC, or to the Appellate Division under Order 56A, rule 3 of the ROC, or to the Court of Appeal under Order 57, rule 2A of the ROC, then the application for leave must be brought within 7 days after the decision was made. The notice of appeal must be filed and served within one month after the date on which leave is given to appeal.
If leave to appeal is not required, then the notice of appeal must be issued within 14 days after the decision was made by the General Division and must be served within 7 days of it being issued.
At the time of filing the notice of appeal, the appellant must provide security for the respondent's costs of the appeal pursuant to Order 56A, rule 5(4) (where the appeal is made to the Appellate Division) or Order 57, rule 3(3) (where the appeal is made to the Court of Appeal) of the ROC; and
the commencement of any appeal will not operate as a stay of the proceedings in which the appeal is brought.
Appeals against decisions of the Appellate Division
Civil appeals that have been decided by the Appellate Division may be appealed to the Court of Appeal under Order 57 of the ROC, only with the leave of the Court of Appeal under Section 47 of the SCJA.
The Court of Appeal will consider granting leave to appeal only if the civil appeal raises a point of law of public importance or benefit or relates to a prima facie error in the decision sought to be appealed against. However, no appeals may be brought against any decisions of the Appellate Division in the cases specified in the Ninth Schedule, such as where certain interim orders are made, or where parties had agreed to the making of a consent order, or where the Appellate Division gives or refuses leave to appeal against a decision of the General Division.
The application for leave to appeal must be made to the Court of Appeal under Order 57, rule 2A of the ROC within 7 days after the decision was made. The notice of appeal must be filed and served within one month after the date on which leave is given to appeal.
At the time of filing the notice of appeal, the appellant must provide security for the respondent's costs of the appeal pursuant to Order 57, rule 3(3) of the ROC; and
Appeals against final and interim decisions made by the State Courts
Appeals against decisions of a Registrar or a District Judge / Magistrate in chambers
Any decision of a Registrar may be appealed to a District Judge in chambers, under Order 55B of the ROC.
Decisions of a District Judge or Magistrate in chambers may be appealed to a Judge of the General Division of the High Court in chambers, under Order 55C of the ROC. An application for leave to appeal under section 21(1) of the SCJA must be brought within 7 days after the decision was made if (i) the amount in dispute or the value of the subject-matter does not exceed $60,000, or (ii) the decision was for an order granting leave to defend proceedings / setting aside a default judgment, as specified under the Third Schedule to the SCJA.
where leave to appeal is not required, the notice of appeal must be issued within 14 days after the decision was made, and must be served within 7 days of it being issued;
where leave to appeal is required, the notice of appeal must be filed and served within 14 days from the date on which leave to appeal was given; and
Appeals against the decision of a District / Magistrate's Court
Decisions of a District Court or Magistrate's Court may be appealed to the General Division of the High Court, under Order 55D of the ROC. An application for leave to appeal under section 21(1) of the SCJA must be brought within 7 days after the decision was made if (i) the amount in dispute or the value of the subject-matter does not exceed $60,000, or (ii) the decision was for an order granting leave to defend proceedings / setting aside a default judgment, as specified under the Third Schedule to the SCJA.
where leave to appeal is required, the notice of appeal must be filed and served within 14 days from the date on which leave to appeal was given;
At the time of filing the notice of appeal, the appellant must provide security for the respondent's costs of the appeal pursuant to Order 55D, rule 3(5) of the ROC; and
What are the rules governing enforcement of foreign judgments?
In Singapore, foreign judgments can be enforced both under common law and by way of statutory means.
Under common law, a foreign judgment may be recognised and enforced by commencing a fresh cause of action for the judgment debt under the foreign award. The foreign judgment creates a new and independent obligation for the party against whom judgment has been rendered to pay the sums under the award to the successful party, which is distinct from the original cause of action in the foreign court.
In order for the foreign judgment to be enforceable under common law in Singapore, it must be:
from a court of competent jurisdiction in a foreign country;
final and conclusive on the merits from the court of competent jurisdiction; and
for a definite sum of money.
A defendant may challenge the recognition and enforcement of a foreign judgment under common law on the following grounds:
that the foreign judgment had been procured by fraud;
that the recognition or enforcement of the foreign judgment would be contrary to public policy; and/or
that the foreign judgment had been obtained in breach of natural justice.
Statutory schemes for enforcement
There are 3 applicable statutes for the enforcement of foreign judgments, namely the Reciprocal Enforcement of Commonwealth Judgments Act (Cap. 264, 1985 Rev. Ed.) ("RECJA"), the Reciprocal Enforcement of Foreign Judgments Act (Cap. 265, 2001 Rev. Ed.) ("REFJA), and the Choice of Court Agreements Act (Cap. 39A, 2016 Ed.) ("CCAA").
A party that wishes to enforce a foreign judgment under the aforementioned statutes must apply by way of an ex parte originating summons to the Singapore High Court to have the judgment registered. Once registered, the foreign judgment may be enforced in Singapore as if it were a local judgment.
Reciprocal Enforcement of Commonwealth Judgments Act
The RECJA deals with money judgments issued by a court of one of the Commonwealth jurisdictions, including but not limited to the UK, Malaysia, Brunei Darussalam, India and Australia. Judgments obtained in Hong Kong before 30 June 1997 may also be enforced under RECJA. On 5 August 2019, a bill for the repeal of RECJA was read in the Singapore Parliament, but has yet to come into force as at the time of writing in May 2021. Once RECJA has been repealed, judgments previously enforceable under RECJA would be enforced under the REFJA.
Reciprocal Enforcement of Foreign Judgments Act
The REFJA applies to both judgments in any civil proceedings or a judgment or order made in criminal proceedings for the payment of money as compensation to the injured party. The REFJA is not applicable to orders for the payment of taxes or any other criminal penalty. A foreign judgment must be final and conclusive between the parties in order to be enforceable under the REFJA.
As at the time of writing in May 2021, REFJA is only applicable to judgments and orders issued by the courts of the Hong Kong Special Administrative Region. The ambit of the EFJA is to be expanded to include those countries under the RECJA once it has been repealed.
On 3 October 2019, the ambit of the REFJA was expanded from final judgments only to include interlocutory orders (such as freezing orders) as well. An interlocutory judgment need not be "final and conclusive" for the purposes of registration under the REFJA.
In addition, foreign non-money judgments are also now enforceable under REFJA. Such non-money judgments may only be enforced if the Singapore court is satisfied that enforcement of the judgment would be "just and convenient". Whilst the Singapore courts have yet to issue any decision conquering the interpretation of this requirement that the enforcement of the judgment would be "just and convenient", the Singapore Parliament has indicated that an example of when it would not be "just and convenient" to allow enforcement is where such enforcement would give rise to practical difficulties or issues of policy.
Choice of Court Agreements Act
On 25 March 2015, Singapore signed the Hague Convention on Choice of Court Agreements ("Hague Convention"), which was given force of law in Singapore under the CCAA.
Judgments obtained from the courts of the contracting states to the Hague Convention, which includes the member states of the EU, may be enforced in Singapore pursuant to the CCAA. The CCAA is applicable to foreign judgments where there is an exclusive choice of court agreement concluded in a civil or commercial matter.
Can the costs of litigation (e.g. court costs, as well as the parties' costs of instructing lawyers, experts and other professionals) be recovered from the other side?
Costs are awarded in the discretion of the court. In principle, litigation costs are generally recoverable by a successful litigant from the unsuccessful party. This principle applies unless it is evident from the circumstances of the case that some other order should be made. The principle does not cease to apply simply because a successful litigant has raised issues or allegations that have failed. However, a successful litigant could be deprived of the whole or part of his costs where he had caused a significant increase in the length of the proceedings. In extreme cases, if a successful litigant has raised issues or allegations improperly or unreasonably, he might not only be deprived of costs but also made to pay the whole or part of the unsuccessful party's costs.
Full costs of lawyers are usually not awarded. The court commonly fixes what it considers to be reasonable costs. In determining the amount of such costs, reference is often made to scales of costs in the ROC or guidelines in Court Practice Directions. Costs that are fixed are generally conservative. If a court does not fix costs at the conclusion of a hearing or on giving judgment, costs may be assessed in taxation proceedings. The usual approach in such proceedings is for the court assess costs on the "standard basis". In doing so, the court allows a reasonable amount for all costs reasonably incurred. Any doubts as to whether costs were reasonably incurred or reasonable in amount are resolved in favour of the paying party. The court may in exceptional cases, assess costs on a more generous "indemnity basis". This may arise in unusual situations where indemnity costs are contractually provided for or where there has been extreme misconduct by a litigant. On this enhanced basis of taxation, doubts over whether any particular costs should be awarded are resolved in favour of the receiving party.
The court also has the discretion to order reimbursement by the unsuccessful party of the whole or a part of the successful litigant's reasonable out of pocket expenses, filing and stamp fees as well as the fees of experts and other professionals.
What, if any, are the collective redress (e.g. class action) mechanisms?
Where numerous persons have the same interest in any proceedings, representative actions may be commenced and/or continued by or against any one or more of them pursuant to Order 15, rule 12(1) of the ROC.
In Koh Chong Chiah v Treasure Resort Pte Ltd [2013] 4 SLR 1204, the Singapore apex court laid down a 2-stage test governing how such proceedings are to be proceeded with.
First, a threshold requirement to be met is that the claimants must have the "same interest" in the proceedings. To meet this requirement, it needs to be established that the class of represented persons is capable of clear definition and that they would all have the same interest in the relief sought from the court. It suffices that there are one or more significant issues of fact or law common to all the claimants that need to be determined by the court. To this end, the court compares the relative significance of such common issues between the claimants with the significance of the issues which differ between them.
Second, where the "same interest" requirement is satisfied, the court then considers whether to exercise its discretion to discontinue the proceedings in question as a representative action where the overall circumstances of the case so justify.
In Syed Nomani v Chong Yeow Peh [2017] 4 SLR 1064, the Singapore High Court held that the court does not have the power to order that existing proceedings be converted to representative proceedings if the representative proceedings had not already been brought under Order 15, rule 12(1) of the ROC. Claimants intending to pursue representative proceedings should therefore prudently commence a representative action pursuant to Order 15, rule 2(1) of the ROC right at the outset.
Under Order 15, rule 3(2) of the ROC, a judgment or order made in representative proceedings is binding on all parties represented. However, such a judgment or order may not be enforced against any person who is not already a party to the proceedings, except with the permission of the court.
What, if any, are the mechanisms for joining third parties to ongoing proceedings and/or consolidating two sets of proceedings?
A defendant may join third parties to ongoing proceedings by issuing a third party notice pursuant to Order 16, rule 1 of the ROC. A third party notice may be issued by the defendant against a third party where the defendant wishes to (a) claim against a third party for any contribution or indemnity; (b) claim against a third party for any relief or remedy relating to or connected with the original subject-matter of the plaintiff's action and substantially the same as some relief or remedy claimed by the claimant; or (c) have a question or issue relating to or connected with the original subject-matter of the claimant's action determined as between the claimant, the defendant and a third party. The defendant must seek permission of the court to issue a third-party notice, unless the action was begun by writ and the third-party notice is issued before the defendant serves his defence on the claimant.
The court may consolidate two or more disputes under Order 4, rule 1 of the ROC if it is satisfied that (a) some common question of law or fact arises in both or all of the matters; (b) the rights to relief claimed therein are in respect of or arise out of the same transaction or series of transactions; or (c) for some reason a consolidation of proceedings is desirable.
Are third parties allowed to fund litigation? If so, are there any restrictions on this and can third party funders be made liable for the costs incurred by the other side?
Under section 5B(1) of the Civil Law Act, third party funding is only permissible in statutorily prescribed dispute resolution proceedings. Regulation 3 of the Civil Law (Third Party Funding) Regulations 2017 ("3PFR") provides that third parties are only permitted to fund international arbitration proceedings as well as related court and mediation proceedings arising out of or connected with international arbitration proceedings. Regulation 3 of the 3PFR does not allow third parties to fund court litigation proceedings. However, in insolvency situations, our courts have interpreted the former Section 272(2)(c) of the Companies Act (now re-enacted in s 144(2)(b) of the Insolvency, Restructuring and Dissolution Act 2018) to permit the sale of by a liquidator of causes of action of an insolvent company to a third party funder or for funding agreements to be made with such funders to advance claims in court or other dispute resolution process, on behalf of the insolvency estate of a company.
Under Regulation 4 of the 3PFR, the third-party funder must (a) carry on the principal business of the funding of the costs of dispute resolution proceedings to which the third-party funder is not a party; and (b) have a paid-up share capital of not less that S$5 million (or the equivalent amount in foreign currency) or not less than S$5 million (or the equivalent amount in foreign currency) in managed assets.
The Civil Law Act and 3PFR are silent on the structure or terms of the funding agreement. However, the Law Society of Singapore's Guidance Note 10.1.1 on "Third-Party Funding" dated 25 April 2017 recommends that the funding agreement should specify the type of costs that the third-party funder will be funding, and, in particular whether the third-party funder will liable by agreement for costs incurred by the other side. Absent such agreement, costs orders would in the first instance, ordinarily be made against the nominal litigant in the proceedings.
What has been the impact of the COVID-19 pandemic on litigation in your jurisdiction (and in particular, have the courts adopted remote hearings and have there been any procedural delays)?
At the height of the COVID-19 pandemic in Singapore, the Singapore Government imposed a form of a lockdown known locally as the "Circuit Breaker" between 7 April 2020 and 2 June 2020. In that time, all matters fixed for hearing before the Singapore courts were adjourned, unless assessed to be essential and urgent. The implementation of the "Circuit Breaker" resulted in the vacation of many hearings. To prevent a backlog of cases, the Singapore courts dispensed with the mid-year court vacation break in 2020 to deal with the backlog. At the Opening of the Legal Year 2021, it was announced that most of the cases impeded by the circuit breaker had either been fixed for hearing or substantively disposed of.
In the wake of the COVID-19 pandemic, disputes in connection with the disruption of existing contracts appear to be increasing. To cushion the impact of such challenges, the Singapore government introduced legislative relief in a bid to ease the pressure on businesses and individuals under the COVID-19 (Temporary Measures) Act 2020. The Act offered temporary relief to parties of targeted categories of contracts, including certain secured loan facilities, construction or supply contracts (including performance bonds granted pursuant to such contracts), certain types of hire purchase or conditional sales agreements, event contracts, tourism contracts, leases or licences of non-residential immovable property, and sale and purchase agreements or agreements for lease of residential property, and options to purchase. Such legislative intervention has helped reduce or avoid disputes in the types of cases concerned. Some of these measures have been extended into 2021 or otherwise adjusted to address specific lingering issues stemming from the pandemic.
For instance, the construction sector has been hard hit with delay and disrupted project work as well as issues stemming from a shrinking supply of foreign labour and rising manpower costs. The problem is now being further exacerbated after the Singapore Government imposed an entry ban on sourcing of labour from South Asian countries hard hit by the pandemic in April 2021. In an effort to avoid single stakeholder groups in the construction industry carrying an undue share of the burden imposed by the COVID-19 pandemic, the Singapore Government amended the COVID-19 (Temporary Measures) Act on 11 May 2021 to allow contractors to seek monetary relief from project partners for spikes in foreign worker wages that had not been priced into ongoing projects. The amended law would enable project partners to share more equitably in increased foreign manpower costs resulting from the COVID-19 pandemic.
What, in your opinion, is the main advantage and the main disadvantage of litigating international commercial disputes?
There are various advantages in litigating international commercial disputes as opposed to submitting them to arbitration. The primary advantages include economy of costs, the ability to join third parties and ease of conducting multi-party proceedings. In efficient jurisdictions, there is also an advantage in speed in bringing disputes to adjudication. Another advantage is the availability of the right of appeal. This may constitute a substantial advantage over arbitration where parties only have one shot at having their rights determined leaving them with no recourse if issues like errors of law are made in an award. Of late, specialist courts have also emerged around the world to adjudicate on disputes calling for such expertise. The establishment of the SICC in 2015 offers litigants the option of having their disputes decided by a panel of experienced judges comprising specialist commercial judges from Singapore as well as civil law and common law countries. As the SICC is a division of the Singapore High Court, there is a right of appeal to the Singapore Court of Appeal. The Hague Convention of 30 June 2005 also has the potential to radically improve the prospects of international enforcement of civil judgments if it gains widespread accession.
The main disadvantages of litigating international commercial disputes are that parties may face difficulty enforcing domestic judgments abroad. Court litigants also do not have autonomy over shaping how their disputes are to be resolved, the languages to be used, the applicable laws and procedures as well as access to a tribunal having the appropriate industry or professional expertise to determine a given dispute. There may also be concerns over unwanted publicity and loss of privacy or concerns over unwanted dissemination of sensitive commercial information in the course of public trial.
What, in your opinion, is the most likely growth area for disputes for the next five years?
Alternative dispute resolution mechanisms to litigation, such as arbitration and mediation, are likely to remain growth areas for dispute resolution in the next 5 years.
The SIAC announced on 31 March 2021 that 2020 saw the SIAC set a new record of 1,080 new case filings involving parties from 60 jurisdictions. This represents a 125% increase from the 479 new cases filed in 2019. With globalisation and extent of cross-border commercial activities as well as SIAC's reputation as one of the world's leading arbitration institutions, there is expected to be good growth for in the international arbitration sector over the next few years.
There is also likely to be an increased demand for mediation to resolve disputes between international parties. On 12 September 2020, the Singapore Convention on Mediation entered into force. It establishes a uniform framework for enforcement of international settlement agreements arising from mediation of commercial disputes. As of this time of writing, the Singapore Convention on Mediation has been signed by 56 states and the international mediation movement continues to gain traction.
What, in your opinion, will be the impact of technology on commercial litigation in the next five years?
The COVID-19 pandemic has compelled all stakeholders in the legal sector, including the courts, to leverage on technology and pivot towards remote hearings through teleconferencing. As a result, most hearings today take place virtually, without the need for parties to be physically present in court. Given that remote hearings have been welcomed by many court users, it is expected that remote hearings will become the new normal and the courts will continue to adjudicate commercial litigation cases via remote hearings with increasing sophistication as technology evolves.
The rise of technology may also lead to the adoption of new processes to improve productivity in the conduct of commercial litigation cases. At the opening of the legal year in 2021, it was announced that the Judiciary and the Singapore Academy of Law are working closely with the Ministry of Law to promote innovation and technology adoption for the development of Singapore's legal services sector over the next decade. Technology is being tapped to improve search algorithms of research portals and platforms to enhance research productivity. Presentation tools are expected to become more refined, easy to use and efficient.
What, if any, will be the long –term impact of the COVID-19 pandemic on commercial litigation in your jurisdiction?
The COVID-19 pandemic is likely to have a long-term impact on commercial litigation in 3 respects.
First, in view of the continuing uncertainty over the extent and severity of the pandemic, it is expected that the use of remote hearings will continue to be widespread and sustained in civil litigation. A cultural acceptance of such electronic hearings has taken root and its utility is also readily becoming apparent.
Second, following from the above, court users, including the Judiciary and legal practitioners, can be expected to invest more heavily into remote hearing technology. Innovations relevant to improving the efficiency of remote hearings and electronic presentations will likely be more closely examined and adopted, leading to a more technologically savvy legal industry as a whole.
Third, the pandemic has led to some countries that have not adapted readily to non-physical hearing processes closing courts or reducing hearings only to urgent legal matters. This has brought about delay to resolution of disputes in such places. Counsel and clients may begin to shape their thinking over the choice of dispute resolution clauses towards a preference for having disputes heard in countries that have managed to re-tool the bulk of their disputes processes in light of the pandemic or to pivot towards more flexible alternatives like arbitration, where there may be a greater willingness to employ electronic remote proceedings. An impetus may also arise on national courts to move towards adopting international regimes and conventions for recognition and enforcement of judgments abroad in order to be attractive jurisdictions for dispute resolution.
Estimated word count: 9121
Contributing Firm
Mr Randolph Khoo
Deputy Managing Director, Dispute Resolution
randolph.khoo@drewnapier.com The Legal 500
Mr Mahesh Rai
Deputy Head, Construction & Engineering; Director, Dispute Resolution
mahesh.rai@drewnapier.com The Legal 500
Mr Adam Maniam
Director, Dispute Resolution; Director, Competition Law Practice (Disputes)
adam.maniam@drewnapier.com The Legal 500
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Category: Rulings on sport, leisure and entertainment
Mixed farewell parties
What is the ruling on farewell parties where there is free mixing among the sexes? What is the ruling on healing through music?
Ruling on playing a game in which the story has to do with a meteor that falls to earth and brings the dead back to life
Ruling on playing chess on the computer
Parties should not be mixed; it is necessary for there to be parties for men only and parties for women only. Mixing is an evil action and is one of the ways of the people of jaahiliyyah (ignorance) – we seek refuge with Allaah from that.
With regard to healing through music, there is no basis for that, rather it is the action of the foolish. Music is not a healing, rather it is a disease and is based on the use of forbidden (musical) instruments. All of that is a disease of the heart and a cause for deviation of morals. The beneficial treatment which will bring peace to the soul is for the patient to listen to the Qur'aan and useful speeches and sermons. Treatment with music and the like is something which makes people get used to falsehood and makes them more sick, and makes them listen to the Qur'aan and Sunnah and useful preaching even less. There is no strength and no power except with Allaah.
Women swimming
Ruling on subscribing to sports channels only
Haraam issues in modern anaasheed and the conditions of nasheed being permissible
Does the soul come out of the body during sleep?
Dreams and dream interpretation
Minimum distance of travel at which it is permissible not to fast and to shorten prayers
Ruling on dealing with mortgages in a non-Muslim country

redpajama_set_name: RedPajamaCommonCrawl


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Cheaters, Ashley Madison, and why God forbids adultery
Shalom, folks. Every Tuesday, we examine a Biblical commandment and add it to the massive EtzMitzvot visual. This week we continue with our commandments on marriage, examining the prohibition on adultery. I was spurred on to examine this commandment with news of the recent hack of a website promoting adultery.
If there ever was a clear indicator of the cultural decay of the United States, it's that we have a popular website whose copyrighted tagline is, "Life is short. Have an affair."
(Over 37 million members – should we be weeping, or what?)
But, in a brief moment of vigilante moral justice, the cheating website was hacked this week, and the hackers are threatening to release the juicy details of all the would-be cheaters unless the website shuts down immediately.
Upon compromising the site, the hackers claimed to have discovered that the owners of this pro-adultery website are…wait for it…unethical liars! (You don't say!)
In the words of the hackers,
"We expose that ALM management is bullsh** and has made $1.7 million from the fraudulent 'full delete' paid functionality alone..."
Hey, once you've started down the path of promoting adultery, what's a little fraud mixed in?
If the hackers do release the private details of 37 million adulterers…well, let's just say divorce lawyers are about to receive a bumper crop of new clients and fresh cash.
Sick yet? Enough of this trash - let's talk about something righteous, shall we?
Civilizations need Torah
The more I study, the more I internalize the reality that the Torah has a commandment for nearly every important matter in life.
The Torah is God's civilization kit. Sure, we glean commandments for individuals from it, but the Torah is really designed to be implemented in a society. It is a manual for how to create a sustainable and upright and just society.
It should be no surprise, then, that the Torah forbids adultery. Just as it is with homosexuality, adultery undermines a civilization by threatening the family unit – the core building block of societies.
Adultery undermines the family unit through reasons that should be obvious: it breaks up families by destroying a spouse's trust, often resulting in divorce, broken homes, kids growing up without their mom or dad really there. That brokenness is witnessed and experienced by the children, who often perpetuate the cycle in their future marriages.
"How much more likely are children to imitate their parents' infidelity and family dysfunction?"
Broken homes and missing-in-action parents result in broken kids who witness the marital fights, suffer through their parents' divorce, reap the reward of the decreased role of their parents in their life, often required to accept a replacement in the form of a step-mom or step-dad.
These negative influences affect kids for life; how much more likely are they to imitate their parents' unfaithfulness and family dysfunction with their own future spouse?
Fidelity and faithfulness in the Bible
We often use the term infidelity to describe adultery. This is a good term. Fidelity – loyalty, faithfulness – describes the righteous state as defined by God; infidelity describes a lack of faithfulness, disloyalty.
Infidelity is the antithesis of God's faithfulness. In the Hebrew Bible, the Torah is likened to a marriage contract, and God himself is compared to a faithful husband:
Israel broke my covenant,
Even though I was a husband to them.
-Jeremiah 31:32
If God is the faithful husband of his people, a person's own infidelity towards his spouse is all the more egregious, a corrupted reflection of a divine image.
Adultery in the 10 Commandments
There's an old joke about the 7th commandment, "You shall not commit adultery." Moses comes down from Sinai and announces: "I have good news and bad news. The good news is that I got Him down to 10. The bad news is that adultery stays."
It's funny because it reflects a basic truth: fidelity to one's spouse for an entire lifetime is no easy task given the reality of the powerful human sex drive.
Dennis Prager writes in Still the Best Moral Code,
The prohibition on a married person having sex with anyone except his or her spouse is, for many people, the most consistently difficult of the 10 Commandments to observe. The reasons shouldn't be hard to guess.
Prager goes on to list 3 major reasons it's difficult to remain faithful in marriage:
The enormous power of the human sex drive combined with a sex-obsessed culture.
The human desire to love and be loved.
The unfortunate reality of loveless marriages.
These realities cause adultery to abound, making fidelity to one's spouse an almost rare occurrence.
Why is the prohibition on adultery listed with the famous fundamentals, the 10 Commandments?
"Things that undermine the family are consistently and strongly prohibited in the Torah."
Because, like the other 9, it is indispensable to forming and maintaining higher civilization. Adultery threatens the very building block of civilization that the Torah seeks to create. That building block is the family: a married mother and father and their children.
Things that undermine the family – dishonoring mother or father, adultery, incest, homosexuality – are consistently and strongly prohibited in the Torah.
Maimonides' adultery omission
I was surprised to find that in Maimonides' famous listing of 613 commandments, Exodus 20:14's "You shall not commit adultery" is missing. Yes, Maimonides omits the 7th of the 10 commandments from his list.
Instead, he goes to Leviticus 18, the big chapter on sexual prohibitions, which commands the slightly more specific,
"Do not have sexual relations with your neighbor's wife and defile yourself with her."
It's more specific, as it pertains specifically to male adulterers, but the distinction is moot. (As is the case with the prohibition on homosexuality, male homosexuality is specifically listed but both sexes are implied.)
In our big EtzMitzvot visual, I've honored Maimonides' choice of the specific Leviticus 18 over the general Exodus 20, but I've interpreted the commandment in the most general way: Don't commit adultery.
Torah enlightened by Messiah: Yeshua's view of adultery
When the Messiah was giving his fundamentals of the faith teaching, what's become known as the Sermon on the Mount, after asserting the eternal and binding nature of the Torah, he says,
You have heard that it was said, 'You shall not commit adultery.'
But I tell you that anyone who looks at a woman lustfully has already committed adultery with her in his heart.
-Matthew 5:27
This aligns with Messiah's behavior throughout the gospels: rather than cancelling a Torah commandment, as some suppose, he amplifies the commandment, distills the underlying principle, and strengthens the commandment in practice.
And boy, what a strengthening. Let me say for the record, I am an adulterer. I've never actually had sex with anyone besides my wife – thank God for his grace in this – but I have lusted after an uncountable number of women. I'm not going to BS you and tell you otherwise; that's reality, folks. (And I bet it's reality for a vast majority of people reading this!)
I think an honest reading of Yeshua's view of adultery means that things like pornography are a form of adultery. And I think he's right – because in your heart, when you're looking at porn, you're imagining sex with that person; breaking the commandment in your mind and heart.
And, if we're honest, if you're breaking a commandment in mind and heart, it's only a matter of time before your actions follow.
A whole volume could be written about men and our powerful sex drives, and how Torah-honoring disciples of Yeshua should direct those drives. For another time, perhaps.
Torah enlightened by Messiah: Yeshua's view of divorce
Moments after strengthening the commandment on adultery, Yeshua comments that adultery is a valid reason for divorce:
It has been said, 'Anyone who divorces his wife must give her a certificate of divorce.'
But I tell you that anyone who divorces his wife, except for sexual immorality, makes her the victim of adultery, and anyone who marries a divorced woman commits adultery.
-Matthew 5:31-32
I think Yeshua strengthens the Torah again here. He does so by increasing the protection around the family unit, the very thing the Torah works so hard to do in numerous commandments.
He protects the family unit by declaring as invalid divorces for reasons other than serious ones, such as adultery and sexual immorality. He is invalidating "any cause" divorce, thus protecting the family unit.
Disciples of Yeshua need to hear this at least as much as the secular world! It's reported some 50% of Evangelical marriages end in divorce. It's a safe bet that many of those are invalid divorces. Yeshua calls us to something higher, folks.
Some have argued Yeshua's view of divorce is too stringent, for example, not allowing for divorce in cases of abuse. I've found a helpful response in Derek Leman's paper, Messianic Jewish Divorce.
God is all about the family. Families are the building block of society. This is why adultery is strongly prohibited, even listed among the fundamental 10 Commandments.
Messiah amplified the prohibition on adultery by showing the heart of the matter: any person that lusts after another in heart and mind is committing adultery.
Messiah strengthened the family unit further by condemning "any cause" divorce, allowing for divorce only in exceptional circumstances, such as adultery and sexual immorality.
By protecting and strengthening the family unit – a married father and mother and their children – the Torah builds and maintains higher civilization.
Without Torah and without the absolute morality given by God, human beings are a wreck. We don't seek to build goodness or higher society. Instead, we seek whatever feels good. What you end up with is, well, what we have today:
What we end up with is fraudulent liars running websites encouraging 37 million people to have an affair because YOLO.
Folks, would you agree with me that this isn't a good path to happiness? I think it's a path to dissatisfaction in life. I think adultery – heck, all the world's false joys – don't actually do good. I think they lead to a life of lying, cheating, infidelity, personal unhappiness, broken marriages, broken families, broken societies.
So, folks, I'm aiming for the good and holy and righteous things found in the Torah and amplified by Messiah. God help me in this regard! I hope the same for you, fine Kineti reader.
found in commandments hierarchy, marriage


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Birding lost a friend last week with the passing of BT3. If you knew him or knew of him, you almost certainly took a moment to reflect in sadness when you heard the news. If the name is unfamiliar, now is the time to be inspired by this incredible life. This month in honor of Bill, be a little kinder, a little funnier, and little more helpful.
Over 130 bird species have been observed at HANA including more than 70 that nest in the diverse habitats found there. During this field trip we expect to see at least 40 species returning to nest or on their way to northern nesting grounds.
The shoreline of Lake Ontario is a haven for migrating warblers and other passerines. We'll look for those early warblers, such as Palm and Yellow-rumped Warblers, to whet our appetites for the weeks to come.
The Last 30 Days gallery displays images of birds that have been seen in … you guessed it … the last 30 days. This popular gallery helps keep people informed of what birds are being seen where throughout the seasons. All images submitted by RBA Members. Submissions welcome!
The collection of Noteworthy Records tables can be found in the Little Gull Archives. Here, we publish links to the more recent Noteworthy Records and one historical (2004) noteworthy sightings tables.
NEXRAD is used by avid birders and professional ornithologists to track migratory birds. The blue circles in the image above reflect the density of flocks of birds, bats, or insects.
The RBA photo galleries includes images of local area birds submitted by members. Current galleries include: Rochester Area Birds, Montezuma NWR, Owls, Vagrants, and Nesting Birds.
RBA nurtures young people's curiosity in birds and helps them take their skills to the next level while offering a fun, safe environment with other teens/preteens to network and bird together.


Zoe's first birthday has come and gone, but we had so much fun celebrating the special little girl she is growing into!
And although I thought I understood it's meaning at the time, until you have a child of your own, I don't think it's possible to fully grasp exactly that feeling. Motherhood and the love you have for your child is an amazing and powerful thing.
I love nothing more than watching Zoe grow into her own little person. I am so proud of the little girl she is becoming. She is so sweet and gentle, and you can already tell she has a heart of gold. Her love for her family (and her dollies) outweighs everything.
Her smile will light you to the core, it is completely unabashed and full of the happiness and joy she feels inside of her heart. She loves showing her silly side and adores making us smile and laugh.
Her intelligence surprises even me, I cannot believe the wealth of knowledge and understanding she has at such a young age. She has a bright mind, and I can't wait to see what she does with it.
And as beautiful as she is on the inside, that beauty is matched on the outside. Beautiful dark hair frames her delicate little face, big bright eyes draw everyone in, and her sweet and innocent smile is the icing on the cake. I may be biased, but I truly think she is one of the most beautiful babies I have ever laid eyes on.
As her first birthday approached, I found myself thinking a lot about the future. I wonder how her personality will change and grow. I wonder what her favorite food will be (will she have a sweet tooth like her daddy, or love spicy food like her mama?). What will her favorite subject be in school? I wonder what her friends will be like. Will she possess a creative drive like both of us? And what will be her goals and aspirations for her future?
I also love imagining all of the memories we will get to make with her. I am so lucky to have such fond memories from my own childhood. Special family traditions that have been passed down, like reading "Twas the Night Before Christmas every Christmas Eve while gathered around the glowing tree. Family vacations, both near and far, where we got to explore the world, act silly and spend countless hours together, are some of my most treasured memories. And just simple moments, like family movie nights, snuggled on the couch snacking on special treats. These are the things I am looking forward to the most.
With all of these thoughts swirling around in my mind, we worked hard to plan a first birthday party that was as sweet and beautiful and special as she is.
We wanted the party to match her sweet and girly side, so we used a lot of pink, gold and cream. We mixed in a few subtle vintage touches like the vintage mason jar vases filled with perky white and pink tulips and baby's breath, a lace table cloth draped over our new farmhouse bench and a homemade floral crown for the birthday girl. We baked and decorated a beautiful pink ombre cake and topped it with a gold letter Z – the piece de resistance!
I hope you enjoyed this little glimpse into her party, and over the next week or so I'll be sharing all of the pretty little details, like her beautiful foil-pressed party invitations from Minted (I truly cannot wait to share these beauties with you!) and tutorials for her cake and floral crown.
Zoe's party is just lovely. The cake is so beautiful. They say that a child's personality is set by age 6. Isn't that amazing? My kids are 16 and 13 now. I can't believe my daughter is driving. I remember her first birthday just like it was yesterday. This is a special time. Thanks for sharing it.
hey girl love the post! Children are truly gifts from God! Zoe is so precious! Love the decor of the party! I can't wait to have a baby someday! God willing! Love ya!


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Energypedia - History
Energypedia Develops the Mozambique Off-grid Knowledge Hub
With funding from the Green People's Energy for Africa (GBE), energypedia launched a hub focused on renewable energy and energy access sector in Mozambique: the Mozambique Off-grid Knowledge Hub. This hub contains information in English and Portuguese on different energy technologies: solar home systems (SHS), improved cookstoves (ICS), mini grids and productive uses of energy (PUE).
The contents of the portal are featured and discussed together with key stakeholders through a series of webinars dedicated to the current market status of each of the technologies in collaboration with the Mozambican Renewable Energy Association: AMER.
Energypedia Develops New Webinars
In 2019, energypedia launched a series of online seminars on different topics such as the Sustainable Energy in Humanitarian Settings in collaboration with the ICRC and the UNITAR; Mini-grid Series 2019 in partnership with the HPNET and the WISIONS of Sustainability Initiative and the Energy Access Series 2019 in collaboration with the ACCESS coalition.
Energypedia also celebrated 7 years of knowledge sharing. The user base increased to 9,894 registered users and on average 64,000 unique visitors visited energypedia every month. Energypedia also hosted over 4,700 energy articles. The energypedia user survey 2019 also provided insights on our users needs and what can be improved in the future. The team also launched the launched the PMCC portal in collaboration with GIZ Mexico.
Energypedia Grows Further
In 2018, energypedia saw an increase in the number of unique visitors from 41,000 to over 50,000 (on average every month). The registered users also grew from 7,932 to over 8,924 and it now hosts over 4500 articles on renewable energy, energy efficiency, and energy access topics.
Energypedia also became a permanent observer organization to the UNFCC and participated in the Conference of Parties (COP) 24. The team also launched new knowledge products such as the Energy Access Portal (one-stop hub for all energy access information) and hosted new tools such as Solar Powered Irrigation Toolbox (SPIS), Electrification Approaches Tool and Solar Pumping Toolkit. Energypedia also welcomed the Energy for Access Coalition as its new partner.
Energypedia Unveils New Knowledge Products for its Ever-Expanding Audience
In 2017, energypedia developed two new knowledge products: Climate Change Portal for information on climate change related topics and Mini-grid Portal to consolidate all information related to mini-grid issues on energypedia. Along with the mini-grid portal, the team also launched a series of three webinars on micro/mini hydro based mini-grids. In addition to developing new knowledge products, energypedia participated in many international conferences, including the COP23 and the Sustainable Energy for All conference. The team also launched the second energypedia user survey to improve the user's experience on energypedia. In 2017, energypedia also celebrated its 5th birthday with all its users and supporters.
Energypedia also grew from 6800 registered users to 7900 registered users and it now hosts about 4100 articles on renewable energy, energy efficiency and energy access topics.
Energypedia Launches New Portals and Forms New Partnerships
In 2016, energypedia launched two new knowledge products: Micro/mini Hydropower Library (MHL) for publications on micro/mini hydropower as well as Opportunity Database to consolidate the latest opportunities related to financing, awards, call for papers, training courses etc in the off-grid renewable energy, energy efficiency and energy access sphere. The team also revamped the Help portal and the homepage to increase the user friendliness of the platform.
In 2016, energypedia formed many new partnerships and collaborated with other initiatives as well as organizations to promote clean and sustainable energy for all. For a list of all the partners, click here.
Energypedia Promotes Organizational Transparency
In 2015, energypedia launched a new database on energy efficiency project documents called Energy Efficiency Project Resource Center. The energypedia team also conducted the first user survey to improve the user's experience on energypedia.
Furthermore, to promote organizational transparency, energypedia has joined the Initiative Transparente Zivilgesellschaft (Initiative Transparent Civil Society) by the German chapter of Transparency International.
Energypedia Develops New Features
Two new portals, Powering Agriculture and Community Portal and a new database on renewable energy project documents called Renewable Energy Project Resource Center were launched. Energypedia also introduced a new toolbar with new design and features.
Energypedia Develops New Portals and Cooperates with New Partners
By the end of 2013 new information portals such as Solar, Hydro, Wind, Bioenergy, Improved Cooking, Mobility , Countries, Impact, Grid, Productive Use and Financing & Funding were launched. Energypedia also partnered with other prominent organizations to promote knowledge sharing on renewable energy and energy efficiency topics.
Energypedia becomes an Independent Nonprofit Organization
The year 2012 was characterized by huge organizational changes. In July 2011, "energypedia UG (haftungsbeschränkt)" was officially founded as a German non-profit company. However, only in 2012 did this newly created body take over the responsibility for www.energypedia.info. Energypedia has been in charge of its operation and continuous development since March 2012. A month later, the energypedia team started working in their new offices.
Energypedia Opens to the Public
Energypedia's development speeded up quickly in 2011. In April, the first easy-to-use wiki database was installed. The PicoPV Database encompasses a unique collection of more than 90 small photovoltaic systems. Other databases followed like the Total Energy Wiki, a new online grassroots data collection system about energy access, which was developed in cooperation with GIZ and Practical Action.
In spring 2011 energypedia.info was opened to the general public. In September 2011, energypedia became accessible to all web users without prior registration. This was a major step to an open and free knowledge-exchange on the platform.
In this year, energypedia also experienced a tremendous increase in registered energy experts, even though registration was not obligatory for reading rights anymore.
Award-winning EnDev Wiki becomes www.energypedia.info
In May 2010, the EnDev Wiki received the GTZ (now GIZ) quality award. Shortly afterwards energypedia was officially launched as an independent platform on June 8th 2010! However, interested experts still had to register to be able to read and write.
Since then, energy experts, academics and other interested stakeholders all over the world are invited to use it for knowledge exchange and collaboration on renewable energy and energy access issues in developing countries.
Energypedia is Born
In January 2009, EnDev finally launched the internal EnDev Wiki. The number of users increased rapidly as more GIZ staff requested accounts. With the wealth of information developed in the wiki, EnDev decided to open up the wiki to non-EnDev users at the end of 2009. This development led to the idea of launching a general wiki on renewable energy and energy efficiency. The idea of "energypedia" was born.
Development of the EnDev Wiki
After initial positive experiences using the wiki, a concept was developed by EnDev describing the benefits of using wikis for knowledge and project management. As a result a first version of the prospective EnDev Wiki was developed.
Exploration of Web 2.0 Applications
Energypedia was developed within the Dutch-German Energy Partnership "Energising Development" (EnDev) implemented by GIZ (Gesellschaft für Internationale Zusammenarbeit GmbH). It all started end of 2007 when EnDev first tested wikis for internal communication and organization purposes.
Retrieved from "https://energypedia.info/index.php?title=Energypedia_-_History&oldid=381016"


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Q: How to Update Cordova version in Android Studio I recently imported my project over from Eclipse over to Android Studio. I created a gradle as well and everything runs fine. However, I'd like to update my Cordova version because Google Developer Console says my current version is deprecated. I've tried to navigate through CordovaActivity.java and other files to actually find out my version but for some reason it's not visible in Android Studio, but in Eclipse it was definitely visible in the .xml files. I even checked the new gradle files. There is actually no mention of how to update in the documentation for Cordova/Android on google either.
So my question is how do I actually update cordova in Android Studio?
Below is my CordovaLib build.gradle file. It says buildToolsVersion 23.0.2 but that can't be right, I believe 5.4.0 is the latest Cordova version.

A: to update cordova:

*

*open a console and type: cordova -v -> current version is displayed

*type npm update -g cordova
to update cordova in your project:

*Go to your project folder

*type cordova platform update android (or your type of platform)

See the documentation of cordova CLI here.

A: I think u should try netbeans for your project development that helps a lot in updating cordova and plugin using npm cmd to install and update..

redpajama_set_name: RedPajamaStackExchange


Every family of a La Paz Instrumental Music student is considered a La Paz Music Booster family. The La Paz Music Boosters assist the instrumental music program throughout the year to help the students experience a fun and worthwhile year in music! Involving yourself in this organization brings tremendous pride and happiness to all who are involved.
We are looking for volunteers to assist with concert preparation and tear down, chaperones for festivals and concerts, and to help with fundraising efforts throughout the year.
To find out more about us, please join us at our booster meetings! The La Paz Instrumental Boosters rely heavily upon volunteers.


Chat Plugin Displaying "The Moderator has closed this chat session"
I'm getting the error "The Moderator has closed this chat session". I've created a page and used the shortcode to insert a chat. Any help would be appreciated!
are you using the network admin account?
then depending whether you're using in post chat or bottom corner chat.
check the roles/permissions for the chat, if you're network user. tick the network user box.
Forgive me but what is a network user?
I'm logged in with the admin account that was used to create the installation. I don't see "Network user" as an option under Authentication.
sorry, i assumed you were using a multisite install of wordpress. ignore that part since you are only using a single site install.
do you not see the open chat button at all? your settings look correct.
could you possibly switch to the default 2012 theme and see if it works then?


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Dangerous è un singolo dei Cascada, terzo estratto da Evacuate the Dancefloor.

Tracce

Classifiche
Finlandia 10
Paesi Bassi 99
Slovacchia 3
Regno Unito 67

Collegamenti esterni

Singoli del 2009

redpajama_set_name: RedPajamaWikipedia


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Students from Coventry are turning to sugar daddies to pay tuition fees
Sugar babies average a monthly allowance of nearly £3,000
Katy Hallam
Sugar Babies enjoy a life of luxury and Sugar Daddies or Mommas find beautiful members to accompany them at all times. (Image: SeekingArrangement)
Cash-strapped students in Coventry are turning to 'sugar daddies' for help pay tuition fees and rent.
More than 110 students at Coventry University and the University of Warwick have signed up to be 'sugar babies' - a term for those entering into transactional relationships with older men and women in exchange for money, gifts or travel - according to dating website Seeking Arrangement.
The American firm says they rake in £2,910 on average a month.
That means students charged the maximum tuition fee - £9,250 - could cover their yearly education costs in just over three months with the help of their rich benefactors.
The website, which claims to be the "world's largest sugar daddy dating site" and has the slogan 'where beautiful, successful people fuel mutually beneficial relationships', has members in 139 countries.
But the company's latest research shows a shocking number of students at British universities are using its services.
Coventry Universityhas 69 sugar babies signed up, according to the Seeking Arrangement website
More than 475,300 students are signed up over the whole of the UK - and 69 of those are at Coventry University.
Over at the University of Warwick, there are 47 students using the site.
A neighbouring university - the University of Birmingham - was named the 20th fastest growing university for sugar babies in the UK.
There, 214 students are members of Seeking Arrangement.
Do you think being a sugar baby is a good way to fund university?
500+ VOTES SO FAR
Those who sign up through the site can specify exactly what they are looking for - including whether someone smokes, drinks alcohol, how tall they are and more - much like a regular dating site.
But then you can also select if you are looking for an emotional connection, romance or just want to be 'friends with benefits'.
Some of the profiles from sugar babies listed as being students and from Coventry are listed below.
One 18-year-old student wrote: "I'm up for anything, I'm 18. Currently a student. I just want someone to have fun with and spoil me."
Another who said they were 19 wrote: "I am a uni student looking to enjoy my life, have a good time and make money. I am willing to talk to someone if they feel lonely and want someone to talk to or if you want someone to go out and spend time with from time to time in return to be treated welll."
Why students are great for Cov
How much is Cov Uni worth to city?
How much is Warwick Uni worth to city?
Opinion: Students great for city centre
The uni facilities open to public
Another 18-year-old wrote: "You should want to be my sugar daddy if your'e looking for a girl who will keep you on your toes and wanting more whilst you let me live my best life with the help of your generous funds."
Of course, there are many different sugar daddy sites out there, meaning more students from each university could be sugar babies.
It is also up to the individual to fill out their profile, so some people may just lie about where they are from, although that would seem pointless if you are actually trying to meet up with people for money/gifts.
Sugar daddies or mummies from the area are also listed on the map.
A woman who describes herself as a former beauty queen said: "Ex-Beauty Queen - Enjoys a secure comfortable lifestyle. Own outright a nice home/car. Secretary. Lives alone. Kids all grown up."
Another said: "I'm a true gent who loves to wine and dine ladies to the best fine dining, top bars, spas and holidays. I'm shy and quite submissive."
Increasing fees
Brandon Wade, founder and CEO of Seeking Arrangement, said more students were relying on help from strangers to get them through school.
He said: "With little regard from the institutions of the student's inability to pay increasing tuition and living costs in the UK, university students are being forced to find alternative methods to fund their educations.
"Young people understand the importance of a degree and want to achieve their educational goals, but they can no longer depend on traditional means to get through school."
Nudist family need tutor
College staff on strike
How students contribute to neighbourhood
Uni tech helped convict killer mum
On the website it states: "If university students didn't have enough to worry about with tuition fees at a high of £9,250, post-graduation employment holds even more uncertainty.
"The amount of British students seeking Sugar Daddies and Mommies to help alleviate some of that stress grew to 475,320 in 2018.
"The value of an education is undeniable, but students aiming for first-class degrees have been overwhelmed in recent years by continuous tuition increases.
"Furthermore, new legislation now allows universities to raise fees annually until 2020. It's easy to see why students in the UK are seeking wealthy benefactors to help offset education costs.
"Sugar Baby students receive an average monthly allowance of £2,910, which is double the potential amount one can earn working a part-time job at the national minimum wage."
However student advisory site Save the Student has urged caution for those considering entering into such arrangements.
A survey by the group shows around four per cent of students in the UK each year admit being involved in adult work as a way to make money and fund university.
But while many see it is a legitimate line of work, the group worries students are being forced into seeking ways of making money they wouldn't have if they were financially comfortable.
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Leptin Shred is a new fat loss supplement created by a guy named Mike Chang. Find out if Leptin Shred actually works to shred body fat today in our review.
Leptin Shred is a nutritional supplement found online at SixPackShortcuts.com. The supplement promises to raise levels of a hormone called "leptin" in order to give you ripped six pack abs and lean muscle growth.
Priced at around $67 for a 15 day supply, Leptin Shred certainly isn't cheap. The manufacturer claims the high price is validated by the supplement's use of natural ingredients like African mango extract, olive leaf extract, and white willow bark extract, all of which purportedly activate your body's leptin production.
Leptin Shred claims to work by raising levels of leptin.
What is leptin, you ask?
Leptin is a hormone in the body that has recently become a buzzword among weight loss supplement manufacturers. Leptin is often called the "Master Fat Loss Hormone" for its ability to help you lose weight.
When your body's leptin levels are high, you don't crave junk food and your metabolism is very high, which means that you digest food fast and efficiently.
When leptin levels are low, your body craves high-calorie foods and your metabolism slows down to a crawl.
The problem with leptin is that leptin levels are often low when we're dieting. Some people diet so excessively that their body goes into starvation mode. In this mode, it struggles to produce adequate levels of leptin. Instead, your body hangs onto its stored fat in order to survive while constantly telling your body to eat more food.
Put simply, leptin is why most diets fail.
By taking Leptin Shred, you can artificially raise levels of leptin within your body in order to maximize the potential power of your weight loss routine.
The active ingredients in Leptin Shred are thought to stimulate leptin production and kickstart your body's natural weight loss cycles.
The creator of Leptin Shred claims that all of these ingredients have been specifically added to the supplement because they send your leptin levels into orbit (which is a good thing).
In reality, there appears to be minimal scientific evidence for any of these supplements.
For example, there have been numerous studies on African mango (also known as Irvingia gabonensis), olive leaf extract, Synephrine HCL (also known as bitter orange), yohimbe, and white willow bark. Nevertheless, none of these studies have been linked to any weight loss benefits.
Piperine, on the other hand, is included in the supplement to purportedly boost the bioavailability of the other ingredients in the supplement. That may be true, although scientific studies have shown that piperine has few health benefits on its own.
Finally, fucoxanthin is a type of pigment found in brown algae. Out of all the ingredients in Leptin Shred, this is the one backed by the most concrete weight loss research: early studies have shown that fucoxanthin can have a powerful effect on weight loss. Nevertheless, we don't know exactly how much fucoxanthin is in Leptin Shred (it could be 1% of the supplement, or it could be 40%). That makes it difficult to assess how much of an effect fucoxanthin really has on your final weight loss.
Ultimately, the ingredients in Leptin Shred are backed by minimal scientific evidence on average.
Leptin Shred is available online at a price of $67 plus $14.97 shipping and handling.
All purchases come with a 60 day refund policy, although you won't get a refund on the shipping and handling fee. To request a refund, contact Leptin Shred's customer service department at 800-655-8576.
The supplement used to be sold on Amazon as well, although it appears to have been taken off the marketplace.
The problem with Leptin Shred on Amazon was that there were only 2 positive reviews for the supplement, both of which were created by new accounts that only had one previous review.
Meanwhile, the other five reviews were all one star reviews that said things like "Complete waste of money", "not what I was expecting" and "feel no difference".
Making matters worse is that the $69 price on Amazon was for a bottle that only lasted 15 days. Multiple reviewers said this was not enough to judge the supplement's weight loss effects.
Leptin Shred is made by a guy named Mike Chang who runs Mike Chang Fitness, also known as Six Pack Shortcuts. After gaining fame selling eBooks and fitness training manuals online, Mike appears to have branched out into the supplement industry.
Conclusion: Who Should Use Leptin Shred?
Leptin Shred is a pricey nutritional supplement that provides little evidence to back up its claims. "Leptin" is one of the biggest buzzwords in the industry today. Unfortunately, it doesn't seem like you can actually raise leptin levels by consuming any of the so-called "superfoods" within Leptin Shred.
For that reason, it's difficult to recommend Leptin Shred to anyone who genuinely cares about losing weight.
Yes I lost 1″ but only because of my lifestyle change.


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Local Nonprofit Seeks To Make New York The Green City
Filed Under:Catalog Choice, Chuck Teller, Eco-Friendly, Elise Finch, Green City, Green Festival, GrowNYC, Marcel Van Ooyen, Union Square Park
A festival in Union Square Park Wednesday encouraged New Yorkers to be more eco-friendly. (Credit: CBS)
NEW YORK (CBSNewYork) — A local nonprofit the Big Apple to become Green City, and hosted a green fair in Union Square Wednesday to encourage New Yorkers to become more eco-friendly.
As CBS 2's Elise Finch reports, more than 140 interactive exhibits about all things eco-friendly turned Union Square Park from a farmers market into a green fair.
"I'm learning so many new things here by walking through every booth," said Manhattan resident Sipla Kaza.
The free one-day event was sponsored by the nonprofit GrowNYC. The goal is to create a single destination where New Yorkers can learn everything they want to know about going green.
"Whether it's shopping at a farmers market to support regional agriculture, or learn how to recycle better to reduce waste and overall cost, we're here to help New Yorkers make those small changes that will make a big change over time," said Marcel Van Ooyen, executive director at GrowNYC.
Visitors were impressed by the effort.
"It may not put a huge dent or make a noticeable difference right now, but the more people who come on board the better the place will be in the future," said Manhattan resident Steven McClure.
Exhibitors also staged a cook-off to spotlight the benefits of buying locally-produced food. They found clever ways to reinforce basics about concepts such as conservation and recycling.
They also unveiled new products, including an egg that assesses air quality, and a free online service that will save money and trees by eliminating unwanted mail.
"Here I have this junk that we're hauling down to the basement every single day, and sorting and it's a terrible waste," said Manhattan resident Gala Narezo.
Catalog Choice has the solution for that.
"We've built a service that allows you to go right back to thousands and thousands of mailers, and tell them, 'Please don't send me your mail anymore and please don't rent or trade my name,'" said Chuck Teller of Catalog Service.
Every product and service at the event was designed to help New Yorkers turn the Big Apple green, one step at a time.
For more information on the effort, click here.