"The Bolam-Bolitho test is therefore concerned with a potential diversity of views as to the standard of care when a person exercises a special skill (a quasi-normative question), and not with a diversity of views as to causation, which is about what had actually happened (a purely descriptive question)." — Per Andrew Phang Boon Leong JA, Para 75
Case Information
- Citation: [2019] SGCA 75 (Para 0)
- Court: Court of Appeal (Para 0)
- Date: 26 November 2019 (Para 0)
- Coram: Sundaresh Menon CJ; Andrew Phang Boon Leong JA; Judith Prakash JA; Tay Yong Kwang JA; Belinda Ang Saw Ean J (Para 0)
- Case Number: Civil Appeals Nos 70, 71 and 72 of 2018 (Para 0)
- Area of Law: Tort – Negligence – Duty of care – Breach of duty; Tort – Negligence – Causation – Tests for causation; Evidence – Interpretation – Statistical and probabilistic evidence; Civil Procedure – Experts – Presentation tools; Damages – Measure of damages – Dependency; Damages – Measure of damages – Multiplier-multiplicand (Para 0)
- Counsel for the Appellant: Edmund Kronenburg and Crystal Tan (instructed) (Braddell Brothers LLP), Christopher Goh Seng Leong and Seah Wei Jie, Joel (Goh Phai Cheng LLC) (Para 0)
- Counsel for the Respondents: Kuah Boon Theng SC and Vanessa Yong (instructed) (Legal Clinic LLC), Eric Tin, Kang Yixian, Emily Su Xianhui and Kenneth Tan (Donaldson & Burkinshaw LLP) (Para 0)
- Amicus Curiae: Prof Gary Chan Kok Yew (Para 0)
Summary
This appeal arose from a medical negligence claim concerning the misdiagnosis of a lesion removed from Peter Traynor’s back in 2009, which was reported as an intradermal naevus when later evidence showed that it was melanoma. The Court of Appeal considered whether the pathology report was negligent, whether that negligence caused Mr Traynor’s death, and how damages should be assessed if causation were established. The court’s analysis was structured around breach, causation, and damages, with particular attention to the proper role of statistical evidence in medical causation disputes. (Para 2, Para 4, Para 6, Para 7, Para 8, Para 11)
The court upheld the central proposition that the 2009 pathology report was wrong in a legally significant sense, because the original slide was at least suggestive of malignant melanoma and the report should not have given a clean bill of health. It also clarified that the Bolam-Bolitho framework is concerned with breach of duty, not causation, and that causation must be determined by ordinary “but for” principles on the balance of probabilities. Statistical and probabilistic evidence may assist, but it cannot replace the court’s own fact-finding function. (Para 55, Para 68, Para 75, Para 84, Para 108)
On damages, the court addressed the trial judge’s approach to dependency, loss of inheritance, loss of appreciation, and estate claims, including the judge’s view that Mr Traynor would have lived four more years had the breach not occurred. The appellate judgment discussed the multiplier-multiplicand method and the relationship between life expectancy, lost years, and the Civil Law Act, but the provided extract does not contain the final dispositive order or final quantum. The judgment is nevertheless important for its careful distinction between breach and causation and for its treatment of expert and statistical evidence in negligence litigation. (Para 11, Para 12, Para 14, Para 15, Para 70, Para 84, Para 108)
What were the facts leading to the 2009 pathology report and the later melanoma diagnosis?
The factual narrative began in 2009 when Mr Traynor consulted Dr Huang about a mole on his back. A shave biopsy was performed on 12 September 2009, removing the portion of the mole on the skin, and the specimen was sent to Quest Laboratories Pte Ltd for examination and a pathology report. Dr Tan examined the original slide and issued the 2009 pathology report, which diagnosed the lesion as an “ulcerated intradermal naevus.” The court later treated this report as the focal point of the negligence claim because it was the document that conveyed the allegedly erroneous clean bill of health. (Para 22, Para 24)
"On 12 September 2009, Mr Traynor consulted Dr Huang again. This time, a procedure known as a “shave biopsy” was performed on the mole, which removed the portion of the mole on the skin. The biopsied specimen was sent to the 1st Respondent, Quest, for an examination and preparation of a pathology report." — Per Andrew Phang Boon Leong JA, Para 22
The later medical history showed that the lesion did not remain benign. In 2012, after recurrence and further examination, other pathologists identified melanoma. The court noted that the original slide and the later deeper sections were central to the dispute, because the later evidence suggested that the 2009 diagnosis had been mistaken from the outset. The judgment also records that Mr Traynor subsequently died on 6 December 2013, which framed the causation and damages questions in the appeal. (Para 32, Para 42, Para 55)
"After examining the original slide, Dr Tan issued a pathology report (“the 2009 pathology report”). In his pathology report, Dr Tan described the relevant findings as follows: … DIAGNOSIS SKIN LESION, BACK Ulcerated intradermal naevus." — Per Andrew Phang Boon Leong JA, Para 24
The court’s factual discussion also made clear that the 2009 specimen was treated as the primary tumour, and that the later reports were not merely about a separate lesion but about the same underlying pathology. That point mattered because the appeal was not about a hypothetical risk in the abstract; it was about whether the original misdiagnosis deprived Mr Traynor of timely treatment and thereby caused his death. The court’s analysis of the pathology evidence therefore sat at the centre of both breach and causation. (Para 55, Para 68, Para 72, Para 94)
"Mr Traynor subsequently passed away on 6 December 2013." — Per Andrew Phang Boon Leong JA, Para 32
How did the parties frame the negligence claim and the competing causation theories?
The Appellant advanced two related theories. First, she argued that the respondents’ negligence caused a complete loss of cure for Mr Traynor, meaning that on a balance of probabilities he would have been cured had the pathology report been correct. Second, as a fall-back, she argued that the negligence reduced his prospects of cure and that proportionate damages should be awarded for that reduced chance. The respondents resisted both theories and argued that a reduction in prospects was not a recognised head of damage in negligence law. (Para 4)
"The Appellant has two legal strings to her bow. The first (and primary) string is that she is entitled to damages because the alleged negligence of the doctor resulted (on a balance of probabilities) in the loss of a complete cure for Mr Traynor." — Per Andrew Phang Boon Leong JA, Para 4
The respondents’ principal factual position was that Mr Traynor’s fate had already been biologically determined before September 2009 because melanoma had allegedly seeded into distant organs through the bloodstream. On that account, the misdiagnosis did not cause the eventual death, because the disease process was already beyond cure. This was not merely a disagreement about quantum; it was a direct challenge to factual causation and to the proposition that earlier diagnosis would have made a difference. (Para 8, Para 70, Para 72)
"The Appellant’s second (and fall-back) position is that the alleged negligence resulted in the reduced prospects of a cure. The Appellant sought a proportionate award of this reduction in prospects. The Respondents, on the other hand, submitted that a reduction in prospects is not a recognisable head of damage in the law of negligence." — Per Andrew Phang Boon Leong JA, Para 4
The court’s framing of the issues reflected this contest. It identified a Breach Question and a Causation Question, and then broke causation into a sequence of sub-questions that had to be answered chronologically and on the balance of probabilities. That structure was important because it prevented the analysis from collapsing into a single statistical inquiry and required the court to ask what probably happened to Mr Traynor, what treatment was available, whether he would have taken it, and whether it would have cured him. (Para 6, Para 72)
"The Appellant claims that the Respondents had breached their respective duties of care in misdiagnosing her husband’s malignant melanoma in September 2009 (“the Breach Question”). The Appellant further claims that the Respondents’ alleged breach ultimately caused Mr Traynor to pass away from metastatic cancer at the age of 49, when he would have otherwise lived to the age of 82 (“the Causation Question”)." — Per Andrew Phang Boon Leong JA, Para 6
Why did the Court of Appeal hold that the 2009 pathology report amounted to a breach of duty?
The court approached breach by asking what a reasonable and competent pathologist would have done on the material before Dr Tan. It stated that the standard required was that of a reasonable and competent pathologist and that Dr Tan had to diagnose Mr Traynor in a way that at least some responsible body of pathologists would have done. The court’s focus was therefore on professional competence and the defensibility of the report, not on hindsight or on the later causation debate. (Para 53, Para 68)
"The standard required of Dr Tan was that of a reasonable and competent pathologist. It required Dr Tan to have diagnosed Mr Traynor in a way that “at least some responsible body” of pathologists would have done." — Per Andrew Phang Boon Leong JA, Para 53
On the evidence, the court concluded that the original slide was at least suggestive of malignant melanoma. That finding was central because it meant the 2009 report was not merely one defensible interpretation among several; rather, it was wrong in a way that fell below the required standard. The court described the misdiagnosis as a straightforward breach, indicating that the pathology report should not have stated that there was no malignancy when the circumstances required further examination. (Para 55, Para 68)
"The original slide was at least suggestive of malignant melanoma" — Per Andrew Phang Boon Leong JA, Para 55
The court also endorsed the High Court judge’s view that the respondents had been negligent in sending a pathology report indicating a clean bill of health when the circumstances required at least further examination. That conclusion was important because it separated the breach inquiry from the later causation inquiry: the fact that the report was negligent did not itself answer whether the negligence caused death, but it did establish the first element of liability. (Para 7, Para 68)
"The Respondents’ misdiagnosis was a straightforward breach." — Per Andrew Phang Boon Leong JA, Para 68
How did the Court of Appeal explain the proper test for causation in medical negligence?
The court held that causation had to be assessed by ordinary “but for” principles. It stated that it was not enough to show breach; the Appellant also had to show a necessary link, based on the “but for” test, between the respondents’ wrongful conduct and the damage to Mr Traynor. This was a direct rejection of any attempt to treat causation as if it were governed by the same professional-standard inquiry as breach. (Para 70)
"An essential element of the tort of negligence is that of causation. It is not sufficient to show that there has been a breach; the Appellant must also show that there was a necessary link based on the “but for” test between the Respondents’ wrongful conduct and the damage to Mr Traynor" — Per Andrew Phang Boon Leong JA, Para 70
The court then explained that the causation inquiry could be conceptualised chronologically and sequentially. The questions were whether the negligence caused Mr Traynor’s death, whether his fate was biologically determined before September 2009, whether treatment was available, whether he would have taken that treatment, and whether he would have been cured. This sequential structure mattered because each step had to be proved on the balance of probabilities, and failure at any step would defeat the claim. (Para 72)
"The following questions are in fact determinations to be resolved on the balance of probabilities and can be conceptualised chronologically and sequentially:" — Per Andrew Phang Boon Leong JA, Para 72
The court’s reasoning also emphasised that causation is about what actually happened, not about whether a professional opinion was respectable. That distinction led the court to reject the idea that the Bolam-Bolitho test could be imported into causation. In the court’s view, the normative question of professional standards belongs to breach, whereas causation is a descriptive question about historical fact. (Para 75, Para 84)
"The Bolam-Bolitho test is therefore concerned with a potential diversity of views as to the standard of care when a person exercises a special skill (a quasi-normative question), and not with a diversity of views as to causation, which is about what had actually happened (a purely descriptive question)." — Per Andrew Phang Boon Leong JA, Para 75
Why did the Court reject the use of the Bolam-Bolitho test for causation?
The court held that the considerations underpinning Bolam-Bolitho are tied to professional standards and breach, not to causation. It reasoned that if the issue is whether a doctor acted in accordance with a responsible body of medical opinion, then professional judgment is relevant; but if the issue is whether the negligence caused the injury or death, the court must determine what actually happened. That is why the court said the Bolam-Bolitho test ought not apply to causation. (Para 75, Para 84)
"By that same token, the considerations underpinning the Bolam-Bolitho test (which are to do with matters of professional standards and breach) ought not apply to the question of causation." — Per Andrew Phang Boon Leong JA, Para 84
This distinction was not merely semantic. It controlled the structure of the appeal because the respondents’ case depended heavily on expert disagreement and on statistical evidence suggesting that the disease had already progressed beyond cure. The court made clear that such material may be relevant evidence, but it does not transform causation into a professional-standard inquiry. The judge must still decide, on the whole of the evidence, whether the negligence probably caused the harm. (Para 84, Para 94, Para 108)
The court’s approach also aligned with its broader treatment of expert evidence. It noted that a judge is not bound to accept an expert’s opinion in its entirety and may choose between competing expert theories if the evidence supports one over the other. But the judge cannot invent a third theory without evidential basis. That principle reinforced the court’s insistence that causation remains a judicial determination, not an exercise in deference to medical consensus. (Para 94, Para 108)
"The court is not bound to accept the opinion of an expert in its entirety, and may choose between the different theories put forward by the experts." — Per Andrew Phang Boon Leong JA, Para 94
How did the Court treat statistical and probabilistic evidence in deciding causation?
The court accepted that statistical evidence can be useful, especially in medical cases where direct proof may be difficult. However, it stressed that statistical evidence is only one piece of the factual probability puzzle. The ultimate inquiry remains an overall assessment of the plaintiff’s and defendant’s respective cases. In other words, statistics may inform the court’s reasoning, but they cannot replace the court’s own fact-finding function or mechanically determine the result. (Para 108)
"Statistical evidence is but one piece of the factual probability puzzle. The ultimate inquiry lies in the overall assessment of the plaintiff and defendant’s respective cases." — Per Andrew Phang Boon Leong JA, Para 108
The court’s discussion of statistical evidence was informed by the expert material placed before it. In the trial below, the respondents’ oncology expert, Prof Chia, and the appellant’s experts, Prof McCarthy and Prof Kirkham, adduced several large-scale studies to support their respective positions. The court did not treat those studies as dispositive. Instead, it used them as part of the broader evidential matrix, alongside pathology findings, clinical observations, and the sequence of events. (Para 94)
"In the trial below, the Respondents’ expert on oncology, Prof Chia, and the Appellant’s experts, Prof McCarthy and Prof Kirkham, adduced several large scale studies to assist their respective cases." — Per Andrew Phang Boon Leong JA, Para 94
The judgment also drew on academic and comparative material to explain why statistical evidence must be handled carefully. The court referred to authorities and texts discussing the distinction between statistical probability and factual causation, and it emphasised that epidemiological or probabilistic evidence does not itself answer the legal question of whether this claimant’s injury was caused by this defendant’s breach. That is why the court insisted on a balance-of-probabilities analysis grounded in the actual facts of the case. (Para 94, Para 108)
"The ultimate inquiry lies in the overall assessment of the plaintiff and defendant’s respective cases." — Per Andrew Phang Boon Leong JA, Para 108
What expert evidence did the court consider on the pathology question?
The court considered a substantial body of pathology evidence. It referred to Dr Tan’s original report, Dr Fong’s later involvement, and the evidence of Dr Kirkham and Prof Joyce Lee, who issued a joint report. That joint report stated that ulceration was extensive, that only a small amount of residual epidermis was present at the edge of the extensive ulcer, that some cells appeared to be maturing towards the base of the lesion, that some mild atypia was present, and that increased cellularity was observed. These findings were relevant because they bore on whether the lesion should have been recognised as malignant in 2009. (Para 42)
"Dr Kirkham and Prof Joyce Lee issued a joint report (“the joint report”) which stated that “[u]lceration was extensive with only a small amount of residual epidermis present at the edge of the extensive ulcer”, “[s]ome of [the] cells appeared to be maturing towards the base of the lesion”, “some mild atypia was present” and “increased cellularity” was observed." — Per Andrew Phang Boon Leong JA, Para 42
The court also considered the role of later deeper sections and later pathology reports, which supported the conclusion that the original diagnosis was wrong. The significance of this evidence was not that the court deferred to later experts, but that the later material helped show that the original slide had features that should have alerted a competent pathologist to malignancy. The court’s reasoning therefore combined the original specimen, the later review, and the expert explanations of what those features meant. (Para 42, Para 55, Para 68)
In addition, the court noted that it was entitled to choose between competing expert theories where the evidence justified it. It cited authorities on expert evidence to support the proposition that the court may accept uncontroverted expert evidence if it is sound, or reject it if it is inconsistent with objective facts or logic. This approach was important because the pathology dispute involved not only medical opinion but also the court’s own evaluation of the slide features and the sequence of events. (Para 94)
"The court is not bound to accept the opinion of an expert in its entirety, and may choose between the different theories put forward by the experts." — Per Andrew Phang Boon Leong JA, Para 94
How did the court deal with the trial judge’s approach to damages, lost years, and dependency?
The trial judge had awarded damages on the basis that, but for the negligence, Mr Traynor would have lived four more years from 2013. The appellate court described this as the judge’s way of dealing with the “lost years” issue, and it noted that the judge had effectively chosen to “leap where Lord Nicholls had leapt” in Gregg v Scott. The Court of Appeal also observed that it was not entirely clear whether the award was based on loss of chance, loss of expectation of life as a matter of loss of income under section 11 of the Civil Law Act, or some other basis. (Para 11)
"It is therefore, with respect, not entirely clear to us if the basis of the Judge’s award as to these “lost years” was predicated on the loss of a chance doctrine, or on a claim for a loss of expectation of life (as a matter of loss of income) under section 11 of the Civil Law Act (Cap 43, 1999 Rev Ed)." — Per Andrew Phang Boon Leong JA, Para 11
The court recorded that the Appellant had claimed under a Dependency Claim, a Loss of Inheritance Claim, a Loss of Appreciation Claim, and an Estate Claim. The judge accepted the amounts claimed up to four years’ worth for each claim, but held that the Appellant had failed to prove that the value of the benefits to herself and her daughters out of the family’s annual expenses were of the conventional percentages laid down in precedents. As a result, the judge removed that amount from the Dependency Claim and awarded $346,677. (Para 12, Para 15)
"The Appellant had claimed under a Dependency Claim for benefits the dependents would have received from Mr Traynor, a Loss of Inheritance Claim for the sums she would have inherited from Mr Traynor, a Loss of Appreciation Claim for the decline in value to the Traynor family’s home, and the Estate Claim for medical, funerary, out of pocket, grant of probate expenses as well as damages for bereavement, pain and suffering." — Per Andrew Phang Boon Leong JA, Para 12
The appellate judgment also noted that the judge dismissed the Loss of Appreciation and Estate Claims because, on his view, Mr Traynor would not have lived to his full life expectancy but would instead have lived four more years, bringing the claim exactly to the date of trial. The extract does not provide the Court of Appeal’s final quantum or final order, but it does show that the appellate court scrutinised the conceptual basis of the damages award and the relationship between dependency, inheritance, and lost years. (Para 14, Para 15)
"He also held that as Mr Traynor would not have lived to his full life expectancy, but would instead have lived four more years, this would have brought the claim exactly to the date of trial. As such, it was not necessary to make a finding on the multiplier-multiplicand and he also dismissed the Loss of Appreciation and the Estate Claims." — Per Andrew Phang Boon Leong JA, Para 14
What did the court say about the sequential questions that had to be answered on causation?
The court made clear that causation was not a single undifferentiated question. Instead, it identified a sequence of factual determinations that had to be resolved on the balance of probabilities. Those determinations included whether the respondents’ negligence caused Mr Traynor’s death, whether his fate had already been biologically determined by September 2009, whether treatment was available, whether he would have taken it, and whether he would have been cured. This sequential approach was designed to ensure analytical discipline and to prevent the court from skipping directly to a statistical conclusion. (Para 72)
"The following questions are in fact determinations to be resolved on the balance of probabilities and can be conceptualised chronologically and sequentially:" — Per Andrew Phang Boon Leong JA, Para 72
That structure also reflected the court’s insistence that each link in the causal chain must be proved. If the disease had already metastasised beyond cure before the misdiagnosis, then the claim would fail at the first or second step. If treatment was available but the deceased would not have taken it, the chain would fail later. If he would have taken treatment but would not have been cured, the claim would still fail. The court’s method therefore required a granular factual inquiry rather than a broad-brush probabilistic assumption. (Para 72, Para 84, Para 108)
This sequential reasoning was especially important in a case involving cancer, where medical evidence may speak in terms of probabilities, survival rates, and treatment outcomes. The court did not deny the relevance of such evidence; rather, it insisted that the legal question remains whether, on the balance of probabilities, this patient would have avoided the harm but for the negligence. That is why the court repeatedly returned to the “but for” test and to the need for an overall assessment of the competing cases. (Para 70, Para 108)
"An essential element of the tort of negligence is that of causation. It is not sufficient to show that there has been a breach; the Appellant must also show that there was a necessary link based on the “but for” test between the Respondents’ wrongful conduct and the damage to Mr Traynor" — Per Andrew Phang Boon Leong JA, Para 70
Why is this case important for medical negligence and expert evidence?
This case matters because it draws a sharp doctrinal line between breach and causation in medical negligence. The court confirmed that Bolam-Bolitho is a breach doctrine, not a causation doctrine, and that causation must be proved by ordinary factual analysis. That clarification is significant for practitioners because it prevents defendants from converting a causation dispute into a professional-consensus dispute and prevents plaintiffs from relying on professional disagreement alone to establish causation. (Para 75, Para 84)
"By that same token, the considerations underpinning the Bolam-Bolitho test (which are to do with matters of professional standards and breach) ought not apply to the question of causation." — Per Andrew Phang Boon Leong JA, Para 84
The case is also important because it explains how statistical and probabilistic evidence should be used. The court accepted that such evidence can assist, but it warned against treating statistics as a substitute for judicial fact-finding. For lawyers, that means epidemiological studies, survival data, and large-scale research may support an argument, but they must still be tied to the facts of the individual patient and the specific causal chain alleged. (Para 94, Para 108)
"Statistical evidence is but one piece of the factual probability puzzle. The ultimate inquiry lies in the overall assessment of the plaintiff and defendant’s respective cases." — Per Andrew Phang Boon Leong JA, Para 108
Finally, the case is practically significant because it shows that a plainly wrong pathology report can amount to a straightforward breach of duty where the slide itself is suggestive of malignancy. That has obvious implications for pathology practice, clinical communication, and litigation strategy. It also illustrates the court’s willingness to engage closely with expert evidence while preserving the judge’s role as the ultimate fact-finder. (Para 53, Para 55, Para 68, Para 94)
"The original slide was at least suggestive of malignant melanoma" — Per Andrew Phang Boon Leong JA, Para 55
Cases Referred To
| Case Name | Citation | How Used | Key Proposition |
|---|---|---|---|
| ACB v Thomson Medical | [2017] 1 SLR 918 | Used as a recent comparison in the introduction | Medicine can help bring life into the world; contextual comparison for medical negligence (Para 1) |
| Gregg v Scott | [2005] 2 AC 176 | Central authority on loss of chance and causation in medical negligence | Majority rejected loss of chance; minority would allow it; relevant to damages and causation discussion (Para 4, Para 11) |
| Bolam v Friern Hospital Management Committee | [1957] 1 WLR 582 | Standard for breach of duty in medical negligence | Professional standard of care; relevant to breach, not causation (Para 75, Para 84) |
| Bolitho v City and Hackney Health Authority | [1998] 1 AC 232 | Addendum to Bolam | Court may reject illogical professional opinion; relevant to breach analysis (Para 75, Para 84) |
| Hii Chii Kok v Ooi Peng Jin London Lucien and another | [2017] 2 SLR 492 | Explained Bolam-Bolitho and its limits | Relevant to breach, not causation (Para 75) |
| Noor Azlin bte Abdul Rahman v Changi General Hospital Pte Ltd and others | [2019] 1 SLR 834 | Used on factual findings before Bolam and on observable features | Questions of fact are for the judge; objective features matter (Para 94) |
| Sunny Metal & Engineering Pte Ltd v Ng Khim Ming Eric | [2007] 3 SLR(R) 782 | Used for “but for” causation | Definition of factual causation in negligence (Para 70) |
| Winfield and Jolowicz, Tort | Edwin Peel and James Goudkamp gen ed, Sweet & Maxwell, 19th Ed, 2014 | Secondary authority | Explains causation and negligence structure (Para 94) |
| Vellino v Chief Constable of the Greater Manchester Police | [2001] 3 All ER 78 | Cited on stages of analysis | Illustrates limits and policy in negligence analysis (Para 94) |
| Neindorf v Junkovic | (2005) 222 ALR 631 | Cited on narrowing inquiries through duty, breach, and damage | Sequential analysis of negligence issues (Para 94) |
| McLean v Weir | [1977] BCJ No 935 | Cited on expert evidence | Court cannot invent a third medical theory without evidential basis (Para 94) |
| Muhammad Jefrry v Public Prosecutor | [1996] 2 SLR(R) 738; also cited as [1997] 1 SLR 197 in the extract | Cited on expert evidence | Court may choose between expert theories (Para 94) |
| Saeng-Un Udom v Public Prosecutor | [2001] 2 SLR(R) 1 | Cited on expert evidence | Court may accept uncontroverted expert evidence if sound (Para 94) |
| Sakthivel Punithavathi v Public Prosecutor | [2007] 2 SLR(R) 983 | Cited on expert evidence | Consistency, logic, and coherence guide acceptance of expert evidence (Para 94) |
| Public Prosecutor v Choo Peng Kuen | [2018] SGHC 230 | Cited on expert methodology | Scrutiny of methodology and objective facts (Para 94) |
| Sienkiewicz v Greif (UK) Ltd | [2011] UKSC 10 | Cited on statistical evidence | Distinction between fact probability and belief probability (Para 94) |
Legislation Referenced
Source Documents
This article analyses [2019] SGCA 75 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the full judgment for the Court's complete reasoning.