Singapore | Application of the Extended Doctrine of Res Judicata in Favour of Non-Parties in Earlier Proceedings

In CIX v DGN [2025] SGCA 10, the Court of Appeal (“CA”) affirmed that the extended doctrine of res judicata (“Doctrine”) would apply to an action before the Court, if the issue in that action could, and ought to, have been raised in an earlier arbitration.  Significantly, for the first time, the CA addressed the circumstance where a party to the later proceeding was not a party to the earlier arbitration, and held that the Doctrine could nonetheless apply if the issue should have been raised in the arbitration. Managing Director of Dispute Resolution Wendell Wong and Director Tay Eu-Yen discuss this decision.

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Wendell Wong

Managing Director, Dispute Resolution / Co-Head, Investigations / Co-Head, Criminal Law Practice
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Tay Eu-Yen

Director, Business Advisory & Dispute Resolution
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