PT Sri Rejeki Isman Tbk and others

PT Sri Rejeki Isman Tbk and three related Indonesian companies (the Sritex Indonesian entities) belonged to a textile group incorporated and headquartered in Central Java. After financial trouble from around 2021 they went through a court-supervised restructuring (a PKPU), and the Semarang Commercial Court ratified a composition plan. When they failed to keep to its repayment schedules, a creditor petitioned to annul it; the court annulled the plan and declared them bankrupt, and the Indonesian Supreme Court affirmed. Curators were appointed and authorised to take all necessary legal measures to enhance the estate in Singapore. According to the applicants' evidence, the companies were under investigation by Indonesian authorities for alleged corruption, fraud and embezzlement, and former personnel had been arrested.

Two Singapore subsidiaries, Golden Legacy Pte Ltd and Golden Mountain Textile and Trading Pte Ltd, had with the Indonesian companies issued senior notes listed on the Singapore Exchange totalling US$725,000,000. The curators said on affidavit they did not know how the proceeds were used or where they went. In Originating Application No 7 of 2026 in the Singapore International Commercial Court, the curators and companies sought recognition of the Indonesian bankruptcy as a foreign main proceeding under the Model Law, as adopted by s 252 of the IRDA, plus three further reliefs: a stay on enforcing security, general investigative powers, and powers to administer the companies' Singapore assets.

1. Whether the Indonesian bankruptcy was a foreign main proceeding entitled to recognition under the Model Law.
2. Whether the court could and should stay the enforcement of security on recognising a foreign liquidation-type proceeding.
3. What test governs a request for general investigative powers that targets no specific person, and whether administrative powers should be granted.

On recognition, the Indonesian bankruptcy law is insolvency legislation, the proceeding was collective, court-supervised and for liquidation, and the curators were foreign representatives. The companies' registered offices were in Indonesia and they were run from there, so their centre of main interests was Indonesia; raising money in Singapore did not displace that presumption.

On the stay, secured creditors normally sit outside a liquidation and are not stayed, as United Securities Sdn Bhd v United Overseas Bank Ltd [2021] 2 SLR 950 reflects. But Art 21(1)(g) allows relief available to a Singapore officeholder, including the judicial management stay, and English authority accepts such a stay in an appropriate case. It should not be the default. It was justified here because the alleged wrongdoing raised concern that security may have been granted illegitimately and the note proceeds were untraced. Requiring leave or the curators' consent adequately protected creditors, who need show only a prima facie case.

On investigation, the applicants sought no coercive orders against named persons, so the test in Re Fullerton Capital Ltd [2024] SGHC 155, built for orders against specific people, did not fit. The right question was whether the relief was necessary to protect the debtors' property or creditors' interests and appropriate, which it was, given the duty to trace the notes. The application would also have met the Fullerton test. Administrative powers likewise served the curators' duty to gather assets and ease their investigations, and the leave condition followed recent practice and was agreed.

The court granted the application, recognising the Indonesian bankruptcy as a foreign main proceeding and granting the extended stay, investigative relief and administrative relief, on the condition that no assets or proceeds be distributed or repatriated out of Singapore without the court's leave.