In KBP Biosciences Pte Ltd and another v Novo Nordisk A/S [2026] SGCA(I) 2, the Singapore Court of Appeal upheld a worldwide freezing order granted by the Singapore International Commercial Court (“SICC”) under section 12A of the International Arbitration Act 1994 (2020 Rev Ed) (“IAA”) in support of a New York-seated International Chamber of Commerce (“ICC”) arbitration.