The sun never sets on English law governed debt: reviewing the Re Prosafe SE decision
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The recent decision in Re Prosafe SE pits the principle of freedom of contract against the increasingly popular modified universalism in the cross-border restructuring and insolvency space.
In this article, A&O lawyers from 5 jurisdictions consider the significance of the decision, highlight practical points of note, consider potential workarounds in respect of the rule in Gibbs and speculate on future schemes of English law governed debt in Singapore, as Singapore continues on its path to become a global restructuring hub.