First known recognition of Indonesian corporate bankruptcy in Singapore

Christopher Sontchi IJ, sitting as a judge in the Singapore International Commercial Court, has handed down his written reasons for recognising the Indonesian corporate bankruptcy proceedings of the Sritex group under the Singapore enactment of the UNCITRAL Model law: Re PT Sri Rejeki Isman Tbk [2026] SGHC(I) 16.

This appears to be the first known recognition of an Indonesian corporate bankruptcy in Singapore; previous known recognition orders have only been granted in respect of Indonesian PKPU and personal bankruptcy proceedings.

The Sritex group was Southeast Asia’s largest vertically integrated textile manufacturer. After a failed PKPU restructuring, an Indonesian court placed various Sritex entities into bankruptcy under Indonesian Law No 37 of 2004. The Indonesian curators of the relevant Sritex entities sought recognition of the bankruptcy in Singapore under the UNCITRAL Model Law as enacted in the Insolvency, Restructuring and Dissolution Act 2020 (IRDA), to enable them to investigate the destination of the proceeds of debt finance raised via note issuances on the Singapore Exchange.

Justice Sontchi granted the recognition application. His decision addresses several points of wider interest (including in England & Wales). In particular:

• His Honour confirmed that while the English courts had an established practice of granting a moratorium on enforcement of security where the foreign proceedings were akin to administration (in England) or judicial management (in Singapore), this practice did not fetter the Court’s power to grant the extended moratorium where the foreign proceedings were akin to liquidation or bankruptcy (as His Honour proceeded to do).
• The decision confirms that foreign office-holders may be granted ‘general’ investigative powers to examine the affairs and assets of an insolvent foreign corporation which are short of coercive orders against specific persons to produce documents. This is a point of practical importance for insolvency practitioners, who may well not be entertained by parties who control information about the affairs of an insolvent without an express order of court confirming their right to that information.

Rabin Kok acted as advocate in the Singapore International Commercial Court (on all issues including those of Singapore law), and the Court noted his “able assistance”.

Rabin appeared alongside and was instructed by Advocates & Solicitors in Singapore: Remy Choo Zheng Xi, Shi Jie Chua and Shann Liew (of RCLT Law Corporation) and Sean Lee, Derrick Teo, and Hui Xuan Lock (of Delta Law Corporation).

Read the full judgment here