6.3.8 The most basic level of characterization is the level between the substance and the process. Procedural matters are always governed by the law of the forum. Substantive issues are appropriate for further characterization for choice of law purposes. The distinction is not necessarily made in the same way as in national law. (4) Exclusive jurisdictional agreements are applied unless there are exceptional reasons” The evidence presented to me has shown that each of the parties expressly insists that it does not wish to accept the jurisdiction or legislation in force of the other party and that it does not reach an agreement on another jurisdiction or other applicable law. Consequently, [the agreement in question] does not contain any applicable law clause or any jurisdiction clause. In addition, neither party intended to provide any advantage to the others with regard to the conclusion of the agreement. If their intention was to create darkness and difficulties for lawyers who will be able to debate in the coming years, they have done well. An injunction is the opposite of a given benefit.
In summary proceedings, the court prohibits a party from doing something. As with a given service, this remedy is rarely granted. 6.3.6 In Singapore`s domestic law, the doctrine of consideration is an essential element of a treaty that was not concluded in the course of an act. However, an agreement that is not supported by consideration may be considered a “contract” for legal choice purposes, since other jurisdictions do not use consideration to resolve the problems that the Common Law uses to resolve that doctrine (Re Bonacina  2 Ch 394). However, the position differs where the floating-jurisdiction clause is bound by a floating law clause. In this case, the Singapore Court of Justice ruled that if the floating jurisdiction clause is too inextricably linked to the floating law clause, the former could not survive on its own. The court interpreted the entire clause to mean that the parties go to a Chinese court when they opt for Chinese law and vice versa for Singapore law and jurisdiction. The Court has also held that the Treaty does not provide for a mechanism of choice between the two courts without the first party. Understanding Part Two in such a way that the parties submitted to both the jurisdiction of China and Singapore contradicted the mere wording of the clause (“the courts of Singapore/or people`s Republic of China”). 6.1.1 The subject matter of conflict-of-laws law or private international law relates to three interrelated issues: (1) If a case concerns cross-border matters, which jurisdiction of the country should deal with the case? (2) What duty is to be applied in order to determine the outcome of a dispute in the main proceedings concerning cross-border matters? (3) What is the effect of a judgment rendered by the court of one country before the courts of another country: is it recognized or enforced? 6.2.42 The SICC is exclusive or not. . .