Singapore High Court: Setting aside application of an award unsuccessful - no breach of natural justice where tribunal resolves larger questions under which a subsidiary issue is pleaded or argued

In CYE v CYF [2023] SGHC 275, the Singapore High Court refused to set aside a SIAC arbitration award under Sec. 48 of the Arbitration Act 2001, rendered by a sole arbitrator, finding that there was no breach of natural justice and the award was not induced or affected by fraud, nor contrary to public policy.

According to the High Court, where a party raises an issue as part of a wider claim rather than as a standalone claim (“subsidiary issue”), it would suffice from a natural justice perspective for the tribunal to resolve the larger questions under which the subsidiary issue was raised, as the tribunal would have in effect determined the subsidiary issue. There is no necessity to deal with the issue expressly, specifically or in great detail.

The High Court’s judgment once again reiterates the court's adherence to the principle of minimal curial intervention.