On July 13, 2011, the decision of the Singapore High Court in PT Perusahaan Gas Negara (Persero) TBK v. CRW Joint Operation, No.  SGHC 202 was endorsed by the Singapore Court of Appeal (CRW Joint Operation v. PT Perusahaan Gas Negara (Persero) TBK  SGCA 33). Chris Seppälä examines this decision and concludes that the result is that a perfectly sound award of an ICC arbitral tribunal enforcing a Dispute Adjudication Board decision in favor of a contractor under the FIDIC Conditions of Contract for Construction, 1999 has been definitively set aside in Singapore on the basis of reasoning which is, with respect, flawed in several respects.
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