THE WAVE STUDIO PTE. LTD. & 2 Ors v GENERAL HOTEL MANAGEMENT (SINGAPORE) PTE LTD & Anor

"Having considered the evidence and parties’ submissions, I found that copyright in the Final Photographs was owned by the relevant Wave entities listed in Annex F to the plaintiffs’ closing submissions, and not by the Hotels." — Per Mavis Chionh Sze Chyi J, Para 50

Case Information

• Citation: [2022] SGHC 142 (Para 0)
• Court: General Division of the High Court of the Republic of Singapore (Para 0)
• Date of Judgment: 16 June 2022 (Para 0)
• Coram: Mavis Chionh Sze Chyi J (Para 0)
• Case Number: Suit No 175 of 2018 (Para 0)
• Area of Law: Copyright law; ownership of copyright in commissioned photographs; implied licence; infringement; equitable defences (Paras 27, 29-32)
• Counsel for the Plaintiffs: Not answerable from the extraction (NOT ANSWERABLE)
• Counsel for the Defendants: Not answerable from the extraction (NOT ANSWERABLE)
• Judgment Length: Not answerable from the extraction

Summary

This dispute concerned copyright in hotel photographs created over a long commercial relationship between the Wave entities and hotels managed by General Hotel Management (Singapore) Pte Ltd. The court described the controversy as one about “the copyright in photographs produced over the course of the parties’ working relationship, which spanned over a decade,” and the plaintiffs’ case was that they owned the copyright in the Hotel Photographs and that the defendants had used them without permission in “The Magazine” and online (Paras 1, 19, 16). The court ultimately ruled for the plaintiffs at trial (Para 3).

The court held that copyright in the Final Photographs belonged to the relevant Wave entities, not the Hotels, and that the Hotels had accepted Wave’s reservation of copyright in the Final Photographs (Paras 50, 80). It also held that the defendants did not have an implied licence to use the photographs for general branding, marketing and advertising purposes, and rejected the defendants’ reliance on implied assignment, laches, acquiescence and estoppel by convention (Paras 24, 27, 50). The court’s reasoning turned on the evidence of how the photo-shoots were commissioned, how the photographs were edited and delivered, and what the parties’ documents said about copyright ownership (Paras 41, 44, 67, 78, 80).

Statutorily, the court analysed the Copyright Act’s default ownership rule and its exceptions, including the provisions dealing with photographs and works made in the course of employment or pursuant to a valuable-consideration agreement for the taking of a photograph (Paras 29-32, 38). It quoted the text of s 30(5) and s 30(6) in full, and also relied on the principle that a party is bound by signed contractual terms even if unread, which it used to support its conclusion that the Hotels had accepted the Reservation Clause in the Production Estimates (Paras 38, 78, 80).

How did the court frame the issues in this copyright dispute?

The court framed the dispute in four principal issues: whether the plaintiffs owned the copyright in the Hotel Photographs; whether the defendants had an implied licence to use the Hotel Photographs for general branding, marketing and advertising purposes; whether the defendants had infringed the copyright in the Hotel Photographs; and whether laches, acquiescence and estoppel by convention were available to the defendants (Para 27). The court further divided the ownership question into two sub-issues: who owned the copyright when the photographs were created, and who was the present owner for purposes of the suit (Para 28).

"In the trial before me, the issues to be determined were as follows: (a) Whether the plaintiffs owned the copyright in the Hotel Photographs; (b) Whether the defendants had an implied licence to use the Hotel Photographs for general branding, marketing and advertising purposes; (c) Whether the defendants had infringed the copyright in the Hotel Photographs; and (d) Whether the defences of laches, acquiescence and estoppel by convention were available to the defendants." — Per Mavis Chionh Sze Chyi J, Para 27

The court’s decision to split ownership into creation-time ownership and present ownership mattered because the plaintiffs’ case depended not only on showing that Wave or Ms Lee initially owned the copyright, but also on showing that the copyright had been validly assigned through a chain of assignments to the third plaintiff (Paras 19, 28). That structure also explains why the judgment spent substantial time on the commissioning arrangements, the role of the photographers, the editing process, and the Reservation Clause in the Production Estimates (Paras 41, 44, 67, 80).

In addition, the court’s framing shows that the defendants’ case was not limited to denying ownership. They also advanced alternative defences based on implied licence and equitable doctrines, which meant the court had to examine both the contractual and equitable dimensions of the parties’ long-running commercial relationship (Paras 24, 27). The judgment therefore addressed not just who owned the copyright, but also whether the defendants could lawfully use the photographs even if they did not own them (Paras 24, 50).

What were the key facts about the parties’ long commercial relationship and the creation of the Hotel Photographs?

The court found that between 1995 and 2008, Ms Lee and the Wave entities were engaged by GHM to provide a range of services to the Hotels, including the production of marketing, branding and promotional materials (Para 10). The relationship was not confined to photography; rather, it encompassed a broader suite of branding and design services, which later became important when the court considered whether the photography work fell within a statutory commissioning arrangement for the taking of photographs (Paras 10, 60).

"Between 1995 and 2008, Ms Lee – as well as the Wave entities – were engaged by GHM to provide an array of services to the Hotels which included the production of marketing, branding and promotional materials (“marketing collaterals”) for the Hotels." — Per Mavis Chionh Sze Chyi J, Para 10

The court accepted that the Hotel photo-shoots involved photographers engaged by Wave, and that Ms Lee edited the Raw Images into Final Photographs before those Final Photographs were delivered on CD-ROMs to the second defendant and the Hotels (Paras 13, 41). The court’s factual findings on this process were central to the ownership analysis because they showed that Wave, not the Hotels, was the entity organising and commissioning the photographic work, and that the final deliverables were the product of Wave’s editing and production process (Paras 41, 44, 60).

"After this editing process, CD-ROMs containing the Final Photographs would be delivered to the second defendant and the Hotels." — Per Mavis Chionh Sze Chyi J, Para 13

The dispute surfaced years later when Ms Lee discovered that the Hotel Photographs had been used in GHM’s in-house publication, “The Magazine,” and on websites. The judgment records that between 18 January 2013 and 30 June 2013, she discovered 242 instances of the Hotel Photographs in Issues 1 to 12 of “The Magazine” (Para 16). That discovery triggered the copyright claim, because the plaintiffs said the defendants had reproduced and communicated the photographs without permission and outside any licence that might have existed (Paras 16, 19, 24, 27).

"Subsequently, between 18 January 2013 and 30 June 2013, she discovered that the Hotel Photographs had appeared on 242 instances in Issues 1 to 12 of GHM’s in-house production, “The Magazine”" — Per Mavis Chionh Sze Chyi J, Para 16

Who owned copyright in the Raw Images when the photographs were first taken?

The court held that the authors of the Raw Images were the photographers who physically took the photographs at the Hotel photo-shoots, namely Mr Kawana and Mr Lim (Para 37). But authorship was not the same as ownership for the purposes of the dispute. The court had to determine whether the Hotels, Wave, or some other entity acquired copyright under the Copyright Act’s default rule or one of its exceptions (Paras 29-32, 37).

"On the evidence before me, I was satisfied that Mr Kawana and Mr Lim – as the persons who had taken the photographs at the Hotel photo-shoots – were the authors of the Raw Images." — Per Mavis Chionh Sze Chyi J, Para 37

The court then examined the statutory framework. It noted that s 4 of the Copyright Act provides that, subject to the Act, no copyright shall subsist otherwise than by virtue of the Act, and that photographs fall within “artistic works” under s 7 (Paras 29-30). It also stated the default rule that the author of an artistic work is entitled to copyright, subject to the statutory exceptions in ss 30(4) to 30(6) (Para 31). This statutory structure was the starting point for deciding whether the Hotels could claim ownership merely because the photographs were taken for them (Paras 29-31).

"Section 4 of our Copyright Act provides that subject to the provisions of the Act, no copyright shall subsist otherwise than by virtue of the Act." — Per Mavis Chionh Sze Chyi J, Para 29

"The subject matter of this dispute – photographs – falls into the category of “artistic works” as per s 7 of the Copyright Act." — Per Mavis Chionh Sze Chyi J, Para 30

The court also quoted the statutory text of s 30(5) and s 30(6), which govern, respectively, certain commissioned photographs and works made in the course of employment (Para 38). Those provisions mattered because the defendants’ ownership case depended on showing that the Hotels had commissioned the photographs in the statutory sense, or that the relevant work was made under a contract of service. The court ultimately rejected that route on the facts, because the evidence showed that Wave commissioned the photographers and that Mr Lim was engaged by Wave, not by the Hotels (Paras 41, 44, 60).

"(5) Subject to subsection (4), where — (a) a person makes, for valuable consideration, an agreement with another person for the taking of a photograph, the painting or drawing of a portrait or the making of an engraving by the other person; and (b) the work is made in pursuance of the agreement, the first-mentioned person shall be entitled to any copyright subsisting in the work by virtue of this Part, except that if the work is required for any particular purpose, that purpose shall be communicated to that other person and that other person shall be entitled to restrain the doing, otherwise than for that particular purpose, of any act comprised in the copyright in the work." — Per Mavis Chionh Sze Chyi J, Para 38

"(6) Where a literary, dramatic or artistic work to which subsections (4) and (5) do not apply, or a musical work, is made by the author in pursuance of the terms of his employment by another person under a contract of service or apprenticeship, that other person shall be entitled to any copyright subsisting in the work by virtue of this Part." — Per Mavis Chionh Sze Chyi J, Para 38

Why did the court hold that Wave, and not the Hotels, commissioned the Raw Images?

The court found that, on the evidence, it was “clearly Wave – and not the Hotels, or even the defendants acting on behalf of the Hotels – who had commissioned Mr Kawana to take the Raw Images at the Hotel photo-shoots” (Para 44). That finding was decisive because it meant the Hotels could not rely on the commissioning rule in s 30(5) to claim copyright in the Raw Images merely by showing that the photographs were taken for their commercial benefit (Paras 38, 44). The court’s reasoning was grounded in the actual commercial structure of the parties’ relationship, not in a formalistic assumption that the hotels were the commissioning party simply because the photographs depicted hotel properties (Paras 10, 41, 44).

"Based on the evidence adduced, it was clearly Wave – and not the Hotels, or even the defendants acting on behalf of the Hotels – who had commissioned Mr Kawana to take the Raw Images at the Hotel photo-shoots." — Per Mavis Chionh Sze Chyi J, Para 44

The court also accepted that Mr Lim was engaged by Wave as the photographer for the various Hotel photo-shoots over the years (Para 41). That evidence reinforced the conclusion that the photographers were working within Wave’s production chain, rather than under a direct commissioning arrangement with the Hotels. The court therefore treated Wave as the entity that organised the shoots and procured the raw photographic material, which supported Wave’s ownership claim at the first stage of the analysis (Paras 41, 44).

"The evidence showed that he was engaged by Wave as the photographer for the various Hotel photo-shoots over the years." — Per Mavis Chionh Sze Chyi J, Para 41

In practical terms, the court’s approach shows that copyright ownership in commissioned photography turns on the real contractual and operational relationship, not on the eventual use of the images or the identity of the subject matter. The Hotels’ role as the commercial beneficiary of the photographs did not, by itself, make them the commissioning party for copyright purposes (Paras 41, 44). That distinction became even more important when the court turned to the Final Photographs, because the editing and delivery process further demonstrated that Wave was providing a broader creative service rather than merely acting as a conduit for the Hotels’ own instructions (Paras 60, 67, 80).

How did the court analyse ownership of the Final Photographs and the Reservation Clause?

The court held that the Final Photographs were owned by the relevant Wave entities listed in Annex F to the plaintiffs’ closing submissions, not by the Hotels (Para 50). This was the central holding on ownership, and it reflected the court’s acceptance of the plaintiffs’ evidence that Wave had reserved copyright in the Final Photographs through the Production Estimates and related documentation (Paras 50, 67, 80). The court’s conclusion was not based on a single document alone, but on the totality of the evidence about how the parties dealt with the photographs over time (Paras 50, 67, 80).

"Having considered the evidence and parties’ submissions, I found that copyright in the Final Photographs was owned by the relevant Wave entities listed in Annex F to the plaintiffs’ closing submissions, and not by the Hotels." — Per Mavis Chionh Sze Chyi J, Para 50

The court reasoned that the arrangement was not one for the Hotels to hire Wave simply to take photographs. Instead, it was an agreement for Wave to provide a “one-stop solution” to the Hotels’ branding, design and marketing needs, with photography being only one component of that broader service (Para 60). That characterisation mattered because it undercut the defendants’ attempt to bring the arrangement within the statutory commissioning rule in s 30(5), which is directed to agreements for the taking of a photograph as such (Paras 38, 60). The court therefore concluded that s 30(5) did not operate to vest copyright in the Hotels (Para 60).

"Instead, it was an agreement for Wave to provide the Hotels with a “one-stop solution” to their branding, design and marketing needs; and as Mr Ohletz himself put it, photography was one component of this “one-stop solution”, but photography was not what Wave was hired to do." — Per Mavis Chionh Sze Chyi J, Para 60

The court also found that the Hotels had accepted the Reservation Clause in the Production Estimates (Para 80). It accepted Ms Lee’s evidence that the Production Estimates were issued before the photo-shoots and were accepted by the Hotels, and it relied on the principle that a party is bound by the terms of a contract it signs even if it did not read or understand them (Paras 67, 78, 80). That reasoning meant the Hotels could not later deny the effect of the copyright reservation simply because they had not focused on it at the time (Paras 78, 80).

"I accepted Ms Lee’s evidence that the Production Estimates for the Hotel photo-shoots were issued before the Hotel photo-shoots were carried out, and that they were accepted by the Hotels." — Per Mavis Chionh Sze Chyi J, Para 67

"it is “a well-established principle that in the absence of fraud or misrepresentation, a party is bound by all the terms of a contract that it signs, even if that party did not read or understand those terms”." — Per Mavis Chionh Sze Chyi J, Para 78

"In the circumstances, I was satisfied that the Hotels had accepted the Reservation Clause." — Per Mavis Chionh Sze Chyi J, Para 80

Why did the defendants’ implied assignment and implied licence arguments fail?

The defendants pleaded that the copyright in the Hotel Photographs belonged to the owners of the Hotels, and they also advanced an alternative case that Ms Lee and/or Wave had granted an implied licence to use the Hotel Photographs for general branding, marketing and advertising purposes (Paras 22, 24). The court rejected those contentions because the evidence showed that Wave, not the Hotels, commissioned the work and reserved copyright in the Final Photographs, and because the broader commercial arrangement did not justify implying a licence of the breadth asserted by the defendants (Paras 44, 50, 60, 80).

"The second defendant pleaded that the copyright in the Hotel Photographs belonged to the owners of the Hotels." — Per Mavis Chionh Sze Chyi J, Para 22

"Further and/or in the alternative, the second defendant alleged that Ms Lee and/or Wave had granted the second defendant and/or the owners of the Hotels an implied license to use the Hotel Photographs for general branding, marketing, and/or advertising purposes." — Per Mavis Chionh Sze Chyi J, Para 24

The court’s reasoning on implied licence was closely tied to its factual findings on the nature of the relationship. Because the arrangement was a “one-stop solution” for branding, design and marketing, the court did not accept that the defendants could infer a free-standing licence to use the photographs in whatever way they wished, especially where the documentary evidence pointed to a reservation of copyright by Wave (Paras 60, 67, 80). The court’s approach shows that an implied licence will not lightly be inferred where the parties’ documents and conduct point in the opposite direction (Paras 67, 78, 80).

More broadly, the judgment demonstrates that a defendant seeking to rely on an implied licence must overcome both the express documentary record and the surrounding commercial context. Here, the court found that the Hotels had accepted the Reservation Clause, and that finding was inconsistent with any broad implied licence to use the photographs for general branding, marketing and advertising purposes without restriction (Paras 67, 78, 80). The defendants therefore failed on both ownership and licence (Paras 50, 80).

How did the court deal with infringement and the defendants’ use of the photographs in “The Magazine” and online?

The extraction states that the plaintiffs alleged infringement by use of the photographs in “The Magazine” and on websites, and that the court ruled in favour of the plaintiffs at trial (Paras 16, 3, 19). The court’s ownership findings were the foundation for the infringement analysis, because once the plaintiffs established copyright ownership and the absence of an implied licence, the defendants’ unauthorised reproduction and communication of the photographs in the challenged media became actionable (Paras 50, 80). The judgment excerpt provided does not set out a separate damages assessment, but it does show that liability was resolved in the plaintiffs’ favour (Paras 3, 50).

"At the conclusion of the trial, I ruled in favour of the plaintiffs." — Per Mavis Chionh Sze Chyi J, Para 3

The factual trigger for the claim was Ms Lee’s discovery of 242 instances of the Hotel Photographs in Issues 1 to 12 of “The Magazine” between January and June 2013 (Para 16). That discovery was significant because it demonstrated repeated use rather than an isolated occurrence, and it framed the dispute as one involving systematic exploitation of the photographs in the defendants’ own promotional materials (Para 16). The court’s ownership and licence findings meant that such use was not justified on the basis of any rights held by the defendants (Paras 50, 80).

Although the excerpt does not reproduce a detailed infringement-by-infringement analysis, the structure of the judgment makes clear that infringement followed from the court’s rejection of the defendants’ ownership and licence defences (Paras 27, 50, 80). In other words, the court’s reasoning chain was: Wave owned the copyright in the Final Photographs; the Hotels had accepted the Reservation Clause; there was no implied licence broad enough to authorise the challenged uses; and therefore the defendants’ use of the photographs in “The Magazine” and online was infringing (Paras 50, 67, 80).

Why did the equitable defences of laches, acquiescence and estoppel by convention fail?

The defendants pleaded laches, acquiescence and estoppel by convention as defences to the copyright claim (Para 27). The court rejected those defences, although the excerpt does not provide a separate extended discussion of each doctrine. What is clear from the reasoning is that the court did not accept that the plaintiffs’ delay in objecting, or the parties’ course of dealing, displaced the documentary and factual basis for Wave’s ownership and the Reservation Clause (Paras 50, 67, 78, 80).

The court’s treatment of the signed Production Estimates was especially important to the estoppel analysis. By accepting Ms Lee’s evidence that the Production Estimates were issued before the photo-shoots and accepted by the Hotels, and by invoking the principle that a party is bound by signed terms even if unread, the court effectively foreclosed the argument that the Hotels could rely on a contrary shared assumption about copyright ownership (Paras 67, 78, 80). That reasoning is difficult to reconcile with estoppel by convention in the defendants’ favour, because the documentary record pointed in the opposite direction (Paras 67, 78, 80).

"In the circumstances, I was satisfied that the Hotels had accepted the Reservation Clause." — Per Mavis Chionh Sze Chyi J, Para 80

Similarly, the court’s rejection of laches and acquiescence is consistent with its overall conclusion that the plaintiffs retained copyright and that the defendants’ use was unauthorised (Paras 50, 80). The judgment excerpt does not provide a separate doctrinal exposition of those equitable defences, so any fuller analysis would go beyond the extraction. What can safely be said is that the court did not allow those defences to defeat the plaintiffs’ ownership-based claim (Paras 27, 50, 80).

What statutory principles did the court rely on to resolve copyright ownership in photographs?

The court began from the Copyright Act’s default rule that copyright subsists only by virtue of the Act, and that the author of an artistic work is generally entitled to copyright, subject to statutory exceptions (Paras 29-31). It identified photographs as artistic works under s 7, and then turned to the exceptions in ss 30(4) to 30(6), including the special rule for commissioned photographs in s 30(5) and the employment rule in s 30(6) (Paras 30-31, 38). This statutory framework was the backbone of the ownership analysis (Paras 29-31, 38).

"Under the Copyright Act, the default rule for copyright ownership in an artistic work such as a photograph is that the author of the work shall be entitled to any copyright subsisting in the work (s 30(2) Copyright Act). However, ss 30(4) to 30(6) of the Copyright Act provide for exceptions to this default rule." — Per Mavis Chionh Sze Chyi J, Para 31

The court’s use of s 30(5) was especially important because the defendants’ case depended on treating the Hotels as the commissioning party for the photographs. But the court found that the evidence showed Wave commissioned the photographers, and that the broader arrangement was not simply an agreement for the taking of photographs (Paras 44, 60). As a result, the statutory exception did not transfer copyright to the Hotels (Paras 44, 60).

The court also referred to s 30(6), which deals with works made in the course of employment, but the extraction does not indicate that the Hotels could satisfy that provision on the facts (Para 38). Instead, the evidence pointed to Wave’s engagement of the photographers and to Wave’s role in editing and delivering the Final Photographs, which supported the conclusion that the copyright remained with Wave entities and was later assigned to the third plaintiff (Paras 41, 50, 67). The statutory analysis therefore operated in the plaintiffs’ favour, not the defendants’ (Paras 31, 38, 50).

What cases did the court refer to, and how were they used?

The court referred to several authorities to support its analysis of pleadings, copyright ownership, the definition of a photograph, and contractual assent (Paras 33, 43, 61, 78). The plaintiffs relied on V Nithia for the proposition that the court is precluded from deciding matters not put in issue by the parties, which the court used in the context of pleadings (Para 33). It also referred to Wang Choong Li v Wong Wan Chin on the limits of s 30(5), and to Singsung Pte Ltd v LG 26 Electronics Pte Ltd on the meaning of “photograph,” though the latter point was not finally decided in the excerpt (Paras 43, 61).

"the court is precluded from deciding on a matter that the parties have not put into issue" — Per Mavis Chionh Sze Chyi J, Para 33

The court used Wang Choong Li to illustrate that, absent a direct contractual relationship of the relevant kind, the commissioning party does not acquire copyright under s 30(5) (Para 43). That authority supported the court’s conclusion that the Hotels were not the commissioning party for the Raw Images, because the evidence showed Wave was the entity that commissioned the photographers (Paras 41, 44, 43). The case therefore reinforced the court’s factual and statutory analysis rather than displacing it (Paras 43, 44).

"copyright in the photographs taken by the photographer did not reside in the respondent for the purposes of s 30(5) of the Copyright Act" — Per Mavis Chionh Sze Chyi J, Para 43

The court also cited Singsung Pte Ltd v LG 26 Electronics Pte Ltd in relation to the plaintiffs’ alternative argument about whether edited images could be treated as “photographs,” but the court did not need to decide that issue because it resolved ownership on other grounds (Para 61). Finally, it relied on Bintai Kindenko Pte Ltd v Samsung C&T Corp and another for the principle that a party is bound by signed contractual terms even if unread, which supported the conclusion that the Hotels accepted the Reservation Clause (Para 78). Those authorities were used in a targeted way to support the court’s reasoning on the specific issues before it (Paras 61, 78, 80).

"its views on the definition of a “photograph” were “provisional” and remained “open for further consideration and analysis in an appropriate case”" — Per Mavis Chionh Sze Chyi J, Para 61

"a party is bound by all the terms of a contract that it signs, even if that party did not read or understand those terms" — Per Mavis Chionh Sze Chyi J, Para 78

Why does this case matter for copyright ownership in commissioned commercial photography?

This case matters because it clarifies that copyright ownership in commercial photography depends on the actual commissioning and contractual structure, not merely on who benefits from the photographs or whose premises appear in them (Paras 41, 44, 60). The court’s finding that Wave provided a “one-stop solution” for branding, design and marketing, with photography as only one component, shows that a broader service relationship may fall outside the statutory commissioning rule for photographs (Para 60). That is a significant practical point for businesses that commission creative work as part of integrated branding packages (Paras 10, 60).

"In the circumstances, s 30(5) did not apply so as to vest in the Hotels the copyright in the Final Photographs; the copyright remained with Wave." — Per Mavis Chionh Sze Chyi J, Para 60

The case also underscores the importance of documentary copyright reservations. The court was prepared to accept that the Hotels had accepted the Reservation Clause in the Production Estimates, and it relied on the principle that a party is bound by signed terms even if unread (Paras 67, 78, 80). For practitioners, that means production estimates, quotations and similar pre-shoot documents can be decisive if they clearly reserve copyright and are accepted before the work is done (Paras 67, 78, 80).

Finally, the case is important because it shows how ownership, licence, and equitable defences interact in a copyright dispute arising from a long commercial relationship. The defendants’ attempt to rely on implied licence, laches, acquiescence and estoppel by convention failed against the documentary record and the court’s factual findings (Paras 24, 27, 50, 80). The judgment therefore provides a useful illustration of how courts may protect copyright ownership even where the parties have worked together for years and the photographs have been widely used in marketing materials (Paras 1, 16, 50, 80).

Cases Referred To

Legislation Referenced

• Copyright Act (Cap 63, 2006 Rev Ed) — ss 4, 7, 26(1)(b), 30(2), 30(3), 30(5), 30(6), 31, 32, 119(2)(B), 119(2)(C) (Paras 29-32, 38)

Source Documents

• Original Judgment — Singapore Courts
• Archived Copy (PDF) — Litt Law CDN

This article analyses [2022] SGHC 142 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the full judgment for the Court's complete reasoning.