Lord of the Rings

Sauron, a domiciliary resident of Mordor, owns a precious ring. A thief steals the ring but drowns in a river in Mordor. While fishing in Mordor, Gollum, a domiciliary resident of Wilderland, finds the ring in the river and takes it home to Wilderland. Bilbo meets Gollum in Wilderland and wins the ring from Gollum in a gaming contract, expressed to be governed by the law of Mordor. Bilbo then brings the ring to Singapore where he hands it to Frodo, in consideration for the delivery of share certificates representing shares in Riders Inc, a company incorporated in Rohan. Unknown to Bilbo, Frodo had bought the shares in Wilderland from a thief who had stolen the shares from Gollum.

Assume the following:

Under all relevant laws, a thief obtains no title to stolen chattels, and a finder has good title against everyone but the true owner. Under the law of Wilderland, an exception applies for things found in rivers and lakes, where the finder has good title even against the original owner. The court in Wilderland would apply the law of the finder’s domicile to determine whether the finder has obtained good title.

Gaming contracts are valid and enforceable under the law of Mordor, void and unenforceable under the law of Singapore, and valid but unenforceable under the law of Wilderland. Under all relevant laws, title to property does not pass under a void contract. The court of Wilderland would regard the gaming contract to be governed by the law of Wilderland.

Under the law of Rohan, the shares are transferable by delivery of the certificates, but the transferee cannot get better title than the transferor. Under the laws of Singapore and Wilderland, the share certificates are regarded as negotiable, and delivery of the certificates can give a bona fide purchaser for value without notice a good title even if the transferor has no title. The law of Wilderland but not Singapore regards Frodo as a bona fide purchaser of the shares. In respect of the transaction with Frodo, Bilbo has acted bona fide under all relevant laws.

Now Sauron and Gollum both claim the ring from Frodo. Gollum also claims the shares from Bilbo. Assuming that the claims are heard in Singapore, will they succeed under the rules of private international law of Singapore?