The Court found that the domestic SIAC award at issue had been based on a valid arbitration agreement; accordingly, it rejected Phoenix’s opposition to the ex parte enforcement order, and granted Pertamina’s application for a permanent injunction enjoining Phoenix from continuing with the action it had commenced in the Philippines for a declaration that the SIAC award and arbitration were void. The Court reasoned that Phoenix’s only remedy against the award, consistent with both the UNCITRAL Model Law and the New York Convention, was a set-aside application before the courts of supervisory jurisdiction, that is, the SICC, since the SIAC arbitration had been conducted in Singapore.