Parastate Labs Inc v Wang Li: Stay of Court Proceedings Pending Arbitration
In Parastate Labs Inc v Wang Li and others, the High Court of Singapore granted a stay of court proceedings against Mr. Wang, Mr. Yang, and Babel Holding pending the resolution of arbitration between Parastate Labs Inc and Babel Asia Asset Management Private Limited. The claim involves breach of trustee and/or fiduciary duties, dishonest assistance, fraudulent misrepresentation, and conspiracy. The court's decision was based on principles from Tomolugen Holdings Ltd, emphasizing efficient dispute resolution and preventing abuse of process.
1. Case Overview
1.1 Court
General Division of the High Court1.2 Outcome
Case management stay granted pending resolution of arbitration between Parastate and Babel Asia.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Singapore court grants stay of proceedings against Wang Li and others pending arbitration between Parastate Labs Inc and Babel Asia, focusing on efficient dispute resolution.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Babel Holding Limited | Defendant | Corporation | Case management stay granted | Neutral | |
| Parastate Labs, Inc | Claimant | Corporation | Case management stay granted | Lost | |
| Wang Li | Defendant | Individual | Case management stay granted | Won | |
| Yang Zhou | Defendant | Individual | Case management stay granted | Neutral | |
| Babel Asia Asset Management Private Limited | Defendant | Corporation | Arbitration stay granted | Won |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Andre Maniam | Judge of the High Court | Yes |
4. Counsels
4. Facts
- Parastate invested in the Babel Quant Alpha USDT Fund managed by Babel Asia.
- Parastate and Babel Asia entered into a management agreement with an arbitration clause.
- Babel Finance announced suspension of withdrawals and redemptions.
- Parastate sought to withdraw its Management Assets.
- Parastate framed claims for breach of trustee/fiduciary duties, dishonest assistance, fraudulent misrepresentation, and conspiracy.
5. Formal Citations
- Parastate Labs Inc v Wang Li and others, Originating Claim No 130 of 2022 (Summons No 3651 of 2022), [2023] SGHC 48
6. Timeline
| Date | Event |
|---|---|
| Parastate provided with Babel Finance Presentation Deck | |
| Parastate executed the Management Agreement with Babel Asia | |
| Babel Finance announced suspension of withdrawals and redemptions | |
| Parastate informed Babel Finance of its wish to withdraw Management Assets | |
| Parastate informed Babel Finance of its wish to withdraw Management Assets | |
| Hearing before Andre Maniam J | |
| Case management conference | |
| Case management conference | |
| Judgment issued |
7. Legal Issues
- Stay of Court Proceedings
- Outcome: The court granted a case management stay of the action pending the resolution of the arbitration between Parastate and Babel Asia.
- Category: Procedural
- Sub-Issues:
- Case management stay
- Arbitration stay
8. Remedies Sought
- Monetary Damages
9. Cause of Actions
- Breach of trustee and/or fiduciary duties
- Dishonest assistance
- Fraudulent misrepresentation
- Conspiracy
10. Practice Areas
- Commercial Litigation
- Arbitration
11. Industries
- Financial Services
- Cryptocurrency
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Tomolugen Holdings Ltd and another v Silica Investors Ltd and other appeals | Court of Appeal | Yes | [2016] 1 SLR 373 | Singapore | Cited for the principle that the court should take the lead in ensuring the efficient and fair resolution of a dispute as a whole when part of it is subject to arbitration, and for the factors to consider when deciding whether to stay court proceedings pending resolution of a related arbitration. |
| Reichhold Norway ASA v Goldman Sachs International | N/A | Yes | [1999] CLC 486 | N/A | Cited for the principle that a plaintiff's right to choose whom to sue is not absolute and may be subsidiary to the obligation to arbitrate. |
| Epoch Mineral Pte Ltd v Raffles Asset Management (S) Pte Ltd | High Court | No | [2018] SGHC 223 | Singapore | Cited by Parastate to argue against a stay of proceedings, but distinguished by the court because the facts of that case were different. |
| Epoch Minerals Pte Ltd v Raffles Asset Management (S) Pte Ltd and others | General Division of the High Court | No | [2021] SGHC 288 | Singapore | Cited to summarize the claims for which the plaintiff obtained judgment. |
| Gangadhara Brhmendra Srikanth Maroju v Epoch Minerals Pte Ltd | Appellate Division | No | [2022] SGHC(A) 35 | Singapore | Cited to summarize the claims for which the plaintiff obtained judgment. |
| Mabey and Johnson v Jonathan Laszlo Danos | N/A | No | [2007] EWHC 1094 | N/A | Cited by Parastate to argue against a stay of proceedings, but distinguished by the court because the facts of that case were different. |
13. Applicable Rules
| Rule Name |
|---|
| Order 9 rule 9(7)(i) of the Rules of Court 2021 |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| International Arbitration Act 1994 | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Arbitration
- Stay of proceedings
- Case management stay
- International Arbitration Act
- Management agreement
- Babel Quant Alpha USDT Fund
15.2 Keywords
- arbitration
- stay of proceedings
- case management
- Babel Asia
- Parastate Labs
17. Areas of Law
16. Subjects
- Arbitration
- Civil Procedure