Vol 21 (2024) - Issue 5

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Garuda Indonesia’s Restructuring: Developments in Singapore and Australia

Synopsis
The Singapore International Commercial Court ('SICC'), which officially launched in January 2015, has released its first insolvency-related judgment. The matter of PT Garuda Indonesia (Persero) Tbk and another matter [2024] SGHC(I) 1 is one of the latest in a series of international cases relating to the restructure of Garuda Indonesia (the national airline of Indonesia) and is followed by the High Court of Australia's recent decision in the matter of Greylag Goose Leasing 1410 v PT Garuda Indonesia Ltd [2024] HCA 21. The Greylag Entities have opposed Garuda Indonesia's restructuring in several countries, including the US, France, Indonesia, and Australia. To date only the Indonesian appeals remain outstanding. The Australian and Singaporean cases provide another step forward for Garuda Indonesia as it continues its global restructuring process. This article examines these cases and the insights they can provide into the application of the UNCITRAL Model Law on Cross-border insolvency ('Model Law') in these jurisdictions and lessons for the Australian jurisdiction.