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“Yangtze Harmony”: The practical effects of enforcing bunkers arbitral awards in Rem

Helmsman says Singapore High Court in The “Yangtze Harmony” [2026] SGHC 3 confirmed that the court can lift a ‘stay’ on in rem proceedings, which were put on hold in favor of arbitration.
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In shipping law, in rem proceedings are unique as a claim may be brought against the ship itself as a separate legal entity rather than the owner personally. This is what allows a ship to be arrested and used as security for such a claim.

Earlier this year, the Singapore High Court in The “Yangtze Harmony” [2026] SGHC 3 clarified an unanswered question: whether the court can lift a “stay” on in rem proceedings – which had earlier been put on hold in favor of arbitration. The court has now confirmed that it can. This means that if a party wins an arbitration, it can return to court and enforce the award as a judgment against the ship or its judicial sale proceeds.

Multi-disciplinary law firm Helmsman LLC focuses on the significance of the “Yangtze Harmony” judgment in enforcing arbitral awards in rem proceedings:

Written by Arjun and Shakthi 1

MT: How are arbitration claims against ships usually enforced in Singapore?

In shipping disputes, it is common for a claimant to start court proceedings against a ship to arrest the ship as security, even though the dispute is to be decided by arbitration. These proceedings are then stayed, pending the arbitration’s conclusion, while the claim remains secured in the form of (a) the arrested ship, or (b) its sale proceeds, or (c) any alternate form of security (such as a bank guarantee or an insurer’s letter of undertaking).

Ordinarily, arbitration awards are enforceable only against the parties named in the award (i.e. in personam). If a shipowner fails to pay, the award holder must enforce the award against the shipowner. The significance of the Yangtze Harmony judgment is that it allows an award holder to enforce the award directly against the ship which it previously arrested. This is crucial for cases against one-ship companies where the ship (or its sale proceeds) may be the only meaningful asset for recovery.

MT: If a ship is sold, where do bunker claims rank in getting paid?

While the decision makes enforcement easier, it does not affect the priority in which sale proceeds are distributed. In Singapore, judicial sale proceeds generally satisfy claims in an order of priorities. Higher ranking claims such as dues, Sheriff costs and secured claims are paid first.

A claim for bunkers supplied for a ship’s operation or maintenance are typically considered a statutory lien claim, which ranks at the bottom of the priorities ladder. Bunker suppliers are only paid from whatever funds remain and they share this equally with other similar claimants. A bunker supplier may not know what other high ranking claims exist until after the vessel is arrested or sold. If those claims are substantial, there may be little or nothing left to satisfy bunker claims.

MT: Can bunker suppliers improve their chances of getting paid?

The court has the power to alter the order of priorities when it is equitable to do so, but it is rare and requires evidence of exceptional circumstances. Ordinarily, a claim for the price of unpaid bunkers would not meet this threshold.

While the Yangtze Harmony brings welcome clarity to allow enforcement of arbitral awards as in rem judgments, this does not guarantee recovery, given the risk of priorities. Bunker suppliers in particular should carefully assess the likelihood of being paid in the event of a judicial sale before taking steps such as arresting a ship.

 

Photo credit: Helmsman
Published: 17 June, 2026

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Winding up

Singapore: Xihe Holdings subsidiaries to be wound up voluntarily, creditors to submit claims

Creditors of Da Zhong Tankers and Xin Ying Shipping are required on or before 17 July 2026 to send in their names and addresses and particulars of their debts or claims to appointed liquidators, says notice.
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June 19, 2026

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steve pb from Pixabay

Xihe Holdings Pte Ltd subsidiaries Da Zhong Tankers Pte Ltd and Xin Ying Shipping Pte Ltd will voluntarily wind up following resolutions that were passed by written means, according to a Government Gazette notice published on Thursday (18 June).

The resolutions set out below were duly passed:

  • SPECIAL RESOLUTION – WINDING-UP

That the Company be wound up voluntarily pursuant to section 160(1)(b) of the Insolvency, Restructuring and Dissolution Act 2018.

  • ORDINARY RESOLUTION – APPOINTMENT OF LIQUIDATORS

That Paresh Tribhovan Jotangia and Ho May Kee of Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960 be and are hereby appointed as joint and several liquidators to conduct the said winding-up and that their remuneration be fixed on the usual scale of their professional charges for the work involved.

  • SPECIAL RESOLUTION – POWERS OF LIQUIDATORS

That the liquidators of the Company be authorised to exercise any of their powers given by section 177, 144 (1) and (2) of the Insolvency, Restructuring and Dissolution Act 2018 and to distribute to members, in specie, any part of the assets of the Company.

In another notice, the liquidator of the company said creditors are required on or before 17 July 2026 to send in their names and addresses with particulars of their solicitors (if any) to liquidator Paresh Tribhovan Jotangia at Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960. 

The liquidator may require creditors or their solicitors to “come in and prove their said debts or claims at such time and place as shall be specified in such notice or in default thereof, they will be excluded from the benefit of any distribution made before such debts are proved.”

Related: Singapore: Additional Xihe Holdings subsidiaries to be placed under judicial management

 

Photo credit: steve pb from Pixabay
Published: 19 June, 2026

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Winding up

Singapore: Liquidator of Parakou Shipping issues notice of dividend

Second and final dividend to admitted creditors of Parakou Shipping is payable by 14 July, according to Government Gazette notice.

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June 19, 2026

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A notice of dividend for Parakou Shipping Pte Ltd, which is currently in voluntary liquidation, was published on the Government Gazette on Thursday (18 June). 

The following are the details of the notice:

Name of Company : Parakou Shipping Pte Ltd (In Creditors’ Voluntary Liquidation)
Address of Registered Office : c/o KordaMentha, 50 Raffles Place, 25-01 Singapore Land Tower, Singapore 048623
Amount per centum : 0.55 per centum of admitted claims (in accordance with the Order of Court HC/ORC 4175/2024)
First and Final or otherwise : Second and Final Dividend to admitted creditors (in accordance with the Order of Court HC/ORC 4175/2024)
When payable : By 14 July 2026
Where payable : c/o KordaMentha Pte Ltd, 50 Raffles Place, #25-01 Singapore Land Tower, Singapore 048623

Related: Singapore: Notice of intended dividend issued for Parakou Shipping Pte Ltd

 

Photo credit: Benjamin Child
Published: 19 June, 2026

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Winding up

Singapore: Notice of intended dividend issued for Selco (Shipyard) Pte Limited

Creditors of the companies will have to submit proof of debt to the liquidators of Selco (Shipyard) by 1 July, according to Government Gazette notice.
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June 18, 2026

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A notice to declare the intended dividend of Selco (Shipyard) Pte Limited to its creditors has been posted on the Government Gazette on Wednesday (17 June).

Name of Company : Selco (Shipyard) Pte Limited (In Compulsory Liquidation)
Co. Reg. No.: 196800580K
Address of Registered Office : 7 Straits View, Marina One East Tower, Level 12, Singapore 018936
Court : High Court of the Republic of Singapore
Number of Matter : Companies Winding Up No.: 125 of 1986
Last Day for Receiving Proofs : 1st day of July 2026
Name of Liquidators : Goh Thien Phong and Chan Kheng Tek, Joint and Several Liquidators
Address of Liquidators : c/o PricewaterhouseCoopers Advisory Services Pte Ltd, 7 Straits View, Marina, One East Tower, Level 12, Singapore 018936

 

Photo credit: Jo_Johnston from Pixabay
Published: 18 June, 2026

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