In the recent case of PT Perusahaan Gas Negara (Persero) TBK v CRW Joint Operation [2010] SGHC 202, the Singapore Court considered and set aside a decision of an Arbitral Tribunal ordering PGN to pay CRW US$17m in respect of an award made by a DAB.

The Court analysed the operation of sub-clauses 20.4 to 20.7 of the FIDIC Red Book in situations where a party has filed a Notice of Dissatisfaction, thereby rendering a DAB decision "final but not binding". The Court held that, while it may be open to a party to obtain an interim award in respect of a DAB decision of this type, an Arbitral Tribunal must be asked to review the correctness of a DAB decision before it can make that decision "final and binding".