Partner Katie Chung and Special Counsel Lukas Lim contributed a case report, where in DTM v DTN [2026] SGHC 68, the Singapore High Court dismissed an application to set aside or remit an award to the tribunal on natural justice grounds. The decision reinforces the high threshold for curial intervention in international arbitration and offers practical lessons for practitioners in commodities disputes.

Reproduced from Practical Law with the permission of the publishers. For further information, visit www.practicallaw.com.

The Singapore High Court has dismissed an application to set aside or remit an award to the tribunal on natural justice grounds.
The dispute concerned a contract for sale of iron ore fines (Contract). The buyer argued that the iron content of the cargo supplied was lower than the seller had represented. A third-party umpire resampled the cargo and agreed with the buyer, triggering a price settlement clause under which the buyer claimed a refund. The seller refused to lower its price and the buyer commenced SIAC arbitration, obtaining an award in its favour.

The seller raised three natural justice grounds of challenge in the High Court, all of which were dismissed.

The first argument was that the tribunal had not addressed one of the seller's pleaded defences. The court held that a tribunal was not obliged to deal with every argument and may implicitly resolve issues rendered moot by a logically antecedent determination, as was the case here. The seller's other arguments were that:

• It was denied a fair opportunity to present its case, as the tribunal rejected its request for iron ore chain of custody documents. The court noted that the chain of custody issue was not pleaded and that tribunals enjoy wide procedural discretion. The absence of reasons in the procedural order did not give rise to an "inescapable inference" that the tribunal failed to comprehend the essential issues.
• The tribunal's rejection of its request for transaction data deprived it of a fair chance to prove the prevailing market price. The court held that the seller had ample opportunity to challenge the buyer's evidence, including by cross-examining the buyer's witness or adducing expert evidence, but elected not to do so.

The court also refused to remit the award, holding that remission presupposes an anterior finding of a breach of natural justice justifying set aside, which had not been made out.

The decision offers three helpful reminders:

• All claims/defences and factual issues must be properly pleaded. The chain of custody argument was fatally undermined by the seller's failure to plead it.

• Parties must think carefully before electing not to cross-examine witnesses or adduce expert evidence. The seller's failure to cross-examine and call an expert left the buyer's evidence on market price unchallenged.

• The tribunal's exercise of discretion on document production is difficult to challenge, particularly where the requesting party has not demonstrated that the tribunal acted irrationally or capriciously.

Case: DTM v DTN [2026] SGHC 68 (30 March 2026) (Dedar Singh Gill J).