Civil litigation: Comparative observations
Singapore civil procedure gives a digital-asset claimant three things that Swiss procedure does not: interim relief against third parties on short notice, compelled disclosure from parties and non-parties, and proprietary remedies that survive the defendant's insolvency. Swiss procedure gives the defendant three things that Singapore does not. They are a cost regime in which the loser pays court fees and party compensation according to a tariff instead of actual expenditure, a limited disclosure regime that protects internal documents and the participation rights of the Privatkläger in a parallel criminal case. A claimant with a strong case and a traceable asset should litigate in Singapore where the asset is reachable there. A defendant with a defensible position and Swiss assets should resist Singapore jurisdiction early and litigate at home. Contract drafters between the hubs should decide this question in the dispute-resolution clause before the dispute decides it for them (see Part Q, Chapter III).
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.