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Zhong Shan Strategic Fund v RG Strategy Fund VCC [2025] SGHC 174
A sub-fund of an umbrella VCC may be wound up by the court under the VCC Act. A redemption request does not automatically create a debt if the redemption is suspended under the fund's constitution.
Gan Yuan Hong v LMO Consulting Pte Ltd (Siow Chee Wee, third party) [2025] SGHC 171
A majority shareholder cannot invoke the just and equitable winding up ground under s 125(1)(i) IRDA simply because of a breakdown in relationship with a minority shareholder, especially where the company is a viable going concern and there is no breach of legitimate expectations
Re USP Group Ltd (in judicial management) (United Overseas Bank Ltd, non-party) [2025] SGHC 132
The court may grant sanction for a transaction proposed by judicial managers under s 99(5) IRDA if the judicial managers have the power to act, act honestly and reasonably in the interests of creditors, and there are special reasons or unusual circumstances justifying court sanct
Lim Yan Yi Michelle v Leow Quek Siong and another [2025] SGHC 118
For an express trust to be created, the three certainties (intention, subject matter, and objects) must be present. In the context of bankruptcy, claims of express trusts over assets must be supported by clear evidence of the settlor's intention, and the court will approach such
Re Nagarani d/o Karuppiah (Maybank Singapore Ltd and others, non-parties) and another matter [2025] SGHC 115
The court held that an extension of an interim order under the IRDA requires a serious and viable proposal, and that the claimants failed to demonstrate this as their proposals were contingent on failed schemes of arrangement and faced strong creditor opposition.
Re Taylor, Joshua James and another (Official Receiver, non-party) [2025] SGHC 104
The court held that no trust was created over the cryptocurrencies held by the liquidators, as there was no certainty of intention to create a trust, and legal and beneficial title remained with the customers.
Re Ho Sally (Chan Pik Sun, non-party) and other matters [2025] SGHCR 6
A trustee in bankruptcy must be a person who not only is, but is also reasonably seen to be, independent. A reasonable perception of lack of independence, supported by cogent evidence, may disqualify a prospective trustee.
Maybank Singapore Ltd v Elavarasan s/o Manoharan [2025] SGHCR 4
The Court may exercise its discretion to make a bankruptcy order even if a DRS assessment is ongoing where the debtor's conduct amounts to an abuse of process or is prejudicial to creditors.
National University Hospital (Singapore) Pte Ltd v Soh Keng Cheang Philip and another matter [2025] SGHCR 17
The court has a broad, discretionary power under s 7 of the IRDA to review, rescind or vary its own orders in insolvency proceedings, which should be exercised with caution and only in exceptional circumstances, such as where there is a material change of circumstances or fresh e
Re Chen Weiwen Kelvin (DBS Bank Ltd and another, non-parties) [2025] SGHCR 13
The court held that the sole test for insolvency under Part 14 of the IRDA is the cash flow test, and that a proposal for a voluntary arrangement must be serious and viable to warrant an interim order.
DBS Bank Ltd v Li Yuan [2025] SGHCR 11
A debtor's request for more time to repay a debt does not constitute 'sufficient reason' under s 315(1) of the IRDA to stay bankruptcy proceedings, as it reinforces the debtor's inability to pay and confirms the bankruptcy application is properly maintained.
Tay Lak Khoon v Tan Wei Cheong (as judicial manager of USP Group Ltd) and others [2025] SGCA 41
The court held that there was no due cause for the removal of judicial managers who reasonably relied on legal advice in a situation where the legal position was unsettled, as such reliance did not give rise to a reasonable apprehension of bias.
CH Biovest Pte Ltd v Envy Asset Management Pte Ltd (in liquidation) and others [2025] SGCA 3
The court held that payments made by a Ponzi scheme operator to investors in excess of their principal investment are not contractually owed profits but are non-contractual payments that can be avoided under insolvency avoidance provisions.
Natixis, Singapore Branch v Seshadri Rajagopalan and others and other appeals [2025] SGCA 29
The court held that the judicial managers did not dispose of the vessel as the judicial sale by the foreign court was not a disposal by them, and that a statutory lien created by the issuance of a writ in rem does not constitute a security interest under the IRDA.
Yit Chee Wah and another v Inner Mongolia Huomei-Hongjun Aluminium Electricity Co, Ltd and another appeal [2025] SGCA 27
The court held that in an application to expunge or reduce a proof of debt under r 133(1) of the CIR Rules, the liquidator must show a prima facie case that the proof was improperly admitted, and the court then determines the validity of the debt de novo with the creditor bearing
Affert Resources Pte Ltd (in court compulsory winding up) v Industries Chimiques du Senegal and another [2025] SGCA 19
A transaction for the purpose of s 98 of the Bankruptcy Act is defined widely to include any arrangement, which may comprise a series of associated or inter-connected agreements entered into for a common purpose, even if the parties to the agreements are not identical.
Sapura Fabrication Sdn Bhd and others v GAS and another appeal [2025] SGCA 13
The court affirmed the Wang Aifeng test for carve-outs from moratoria in restructuring proceedings, rejecting an 'exceptional circumstances' test, and held that the court's mandatory obligation to enforce arbitration agreements does not automatically override the insolvency regim
Re Fullerton Capital Ltd (in liquidation) [2025] SGCA 11
The court held that Art 16(3) of the SG Model Law creates a rebuttable presumption that the debtor's COMI is at its registered office, which serves as the starting point for COMI analysis, and that this presumption is rebuttable on the balance of probabilities.
Re Boldtek Holdings Ltd [2024] SGHC 98
The court granted a judicial management order for Boldtek Holdings Limited, finding it unable to pay its debts and that there was a real prospect that judicial management would achieve the purposes set out in s 89(1) of the IRDA.
Zhejiang Crystal-Optech Co Ltd v Crystal-Moveon Technologies Pte Ltd (Moveon Technologies Pte Ltd and another, non-parties) [2024] SGHC 87
A company may be wound up on the just and equitable ground if it has lost its substratum, or under s 125(1)(c) IRDA if it has suspended business for a whole year, provided the court exercises its discretion to do so.
Re Eye-Biz Pte Ltd (in compulsory liquidation) [2024] SGHC 60
The court has the inherent power to ratify the appointment of a solicitor by a liquidator even if the appointment was made before the court's leave was obtained, provided the circumstances justify it.
Re Zipmex Co Ltd and other matters [2024] SGHC 6
The court has no power to grant an extension of a moratorium under s 64(7) of the IRDA where there is no further prospect of a restructuring.
Re Logistics Construction Pte Ltd [2024] SGHC 58
The court held that a disputed liability may in principle be considered a contingent liability where the liability itself is not disputed and the only dispute is over whether the contingency that crystallises the liability has occurred. Furthermore, the court held that the 'major
Affert Resources Pte Ltd (in compulsory winding up) v Industries Chimiques du Senegal and another [2024] SGHC 57
The court held that while the 7 October Letter constituted a transaction at an undervalue, it was not appropriate to make a payment order because the order would not be restorative of the status quo ante.