Can Anti-suit Injunctions Be Extended in Favour of Non-parties? A Review of SGCA’s Decision in Asiana Airlines Ltd. v. Gate Gourmet Korea Ltd. & Ors. [2024] SGCA (i) 8 - Arbitration: The International Journal of Arbitration, Mediation and Dispute Management View Can Anti-suit Injunctions Be Extended in Favour of Non-parties? A Review of SGCA’s Decision in Asiana Airlines Ltd. v. Gate Gourmet Korea Ltd. & Ors. [2024] SGCA (i) 8 by - Arbitration: The International Journal of Arbitration, Mediation and Dispute Management Can Anti-suit Injunctions Be Extended in Favour of Non-parties? A Review of SGCA’s Decision in Asiana Airlines Ltd. v. Gate Gourmet Korea Ltd. & Ors. [2024] SGCA (i) 8 91 2

The right of a non-party to seek anti-suit injunction (ASIs) is a vexed question in international arbitration discourse. Recently, this issue arose before the Singapore Court of Appeal (SGCA) with an interesting twist. That is, can an ASIs be extended to a non-party to shield a contracting party from consequential liability of a foreign judicial proceeding brought in breach of an arbitration agreement? In an interesting take that could potentially shape the debate surrounding this topic, the SGCA has crystallized the position with respect to the issuance of ASIs, including its availability for non-parties to an arbitration agreement. This decision builds upon the existing international jurisprudence concerning the basis for the grant of such injunctive relief to both parties and non-parties, and provides clarity with respect to the extent of legitimate judicial intervention.

Arbitration: The International Journal of Arbitration, Mediation and Dispute Management