Worldwide Freezing Orders in Support of Foreign-Seated Arbitrations – Court of Appeal Upholds US$330m Mareva Injunction

In KBP Biosciences Pte Ltd and another v Novo Nordisk A/S [2026] SGCA(I) 2, the Singapore Court of Appeal upheld a worldwide freezing order granted by the Singapore International Commercial Court under section 12A of the International Arbitration Act 1994 (2020 Rev Ed) in support of a New York-seated International Chamber of Commerce arbitration. The appeal raised important questions concerning the Singapore courts’ power to grant interim relief in aid of foreign-seated arbitrations and the law on Mareva injunctions in Singapore.

In this update, we highlight the key points of the Court of Appeal’s decision and its implications for applicants seeking interim relief in support of international arbitrations. For more information, click here to read the full Update.

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