(d) the exclusive jurisdiction agreement was concluded in a “civil or commercial case”, since the proceedings before the English High Court appeared to be purely commercial; The claimant`s right related to unpaid invoices due to the claimant by the defendant for financial advisory and related professional services provided between the parties in accordance with an order letter. In accordance with the provisions of the agreement concluded between the parties, they had submitted to the exclusive jurisdiction of the English High Court. (1) The comity has little weight when the court decides to apply Agreement 6.2.45 Where the Hague Convention is applicable, its rules of jurisdiction shall apply to the extent that they are inconsistent with the common law or the rules of jurisdiction of the SICC. Therefore, if the Singapore High Court or sicc is the exclusively elected court in a case under the Hague Convention, the High Court or SICC must assume jurisdiction over it, unless the jurisdiction agreement is void and not aerated under Singapore`s private international law. Singapore`s private international law refers to the existing legislation of the jurisdiction agreement to determine its validity. It is not possible to use a “natural forum” or “strong cause”, or even the “appropriate” SICC test. However, States Parties are free to exercise powers of internal attribution of jurisdiction, provided that a delegation without the agreement of the parties may prejudice the recognition and enforcement of the resulting decision in other States Parties. 6.2.23 In the Common Law, a jurisdiction agreement is like any contractual agreement. Fiduciary duty, confidentiality and the duty not to get involved in fiduciary or fiduciary institutions are among the important equitable commitments that may arise today in the commercial context. The Commonwealth is very uncertain about the choice of law for such obligations. The issue is settled by Singaporean law to the extent that, where such an obligation of equity arises from a factual matrix governed by a legally recognised relationship (e..B g.

in an unlawful contract or act), the law governing that underlying relationship applies to the duty of equity ( Rickshaw Investments Ltd v Nicolai Baron von Uexkull [2007] 1 SLR 377). 6.2.44 The Hague Convention has three fundamental characteristics. .