In Valency International Pte Ltd v JSW International Tradecorp Pte Ltd & Ors [2026] SGCA 1, the court dismissed the appeal and held that instructions given to a discharge port agent to release cargo may not amount to an act of conversion unless the claimant can prove the chain of causation between the instructions and the actual act of releasing the cargo, the latter being the event which ultimately crystallised the injury to the claimant’s interest.