In China Medical Technologies v Wu Xiaodong [2018] SGHC
178, Audrey Lim JC held that section 4(10) of the Civil Law Act did
in fact give the Singapore courts the power to grant a Mareva
injunction in aid of foreign court proceedings. In doing so, she
preferred the views of Chan Seng Onn J in Multi-Code Electronics
Industries (M) v Toh Chun Toh Gordon [2009] 1 SLR(R) 1000 over
those of Tay Yong Kwang J (as he then was) in Petroval SA v Stainby
Overseas [2008] 3 SLR(R) 856.
However, Lim JC highlighted the pre-requisites before such power
could be exercised. First, the plaintiff must have an accrued cause
of action against the defendant that is justiciable in a Singapore
court. Second, the Singapore court must have in personam
jurisdiction over the defendant in respect of the Singapore action.
Regarding the first pre-requisite, Lim JC explained that "a
claim is justiciable if it is one for substantive relief which the
court has jurisdiction to grant and is a claim that
