The doctrine of forum non conveniens has evolved over time to balance fairness, convenience, and access to justice. Initially applied in common law systems, its modern interpretation was shaped by key judgments such as the U.S. Supreme Court's Gulf Oil Corp. v. Gilbert (1947), which established the framework for evaluating private and public interest factors, and Sinochem International Co. v. Malaysia International Shipping Corp. (2007), which clarified that the doctrine could be applied before addressing the merits of the case. In the UK, Spiliada Maritime Corp v Cansulex Ltd (1987) set the precedent for determining the "most appropriate forum," emphasizing the respect for the plaintiff's choice of forum. These rulings have made forum non conveniens a flexible, discretionary tool used to ensure cases are heard in the most suitable forum, balancing efficiency, fairness, and access to justice while safeguarding plaintiffs' rights to a fair hearing.
