Case Details
- Citation: [2026] SGFC 31
- Court: Family Court of Singapore
- Date: 11 March 2026 (judgment dated 12 March 2026; reasons supplemented)
- Judges: District Judge Goh Kiat Yi
- Case Title: XZU v XZV
- Proceeding No.: SSP 2336 of 2025
- Plaintiff/Applicant: XZU
- Defendant/Respondent: XZV
- Applicant’s Relationship to Protected Person: Daughter-in-law of the respondent; applicant sought a PPO for her daughter, C
- Respondent’s Relationship to Protected Person: Father-in-law; paternal grandfather of C
- Protected Person: C (15 years old at the time of the application)
- Other Relevant Family Member: D (younger sister of C)
- Legal Area: Family Law — Personal Protection Orders (PPOs) under the Women’s Charter
- Statutes Referenced: Women’s Charter 1961 (including ss 60, 60A, 58B)
- Cases Cited: [2024] SGFC 1; [2024] SGFC 103; [2025] SGFC 135; [2025] SGFC 59; [2026] SGFC 31; [2026] SGFC 8
- Judgment Length: 18 pages, 4,223 words
Summary
In XZU v XZV ([2026] SGFC 31), the Family Court considered an application by a daughter-in-law for a Personal Protection Order (“PPO”) on behalf of her 15-year-old daughter, C, against C’s paternal grandfather. The application was brought under the Women’s Charter 1961 after the introduction of a new family violence regime on 2 January 2025. The court’s task was twofold: first, to determine whether the respondent had committed (or was likely to commit) “family violence” against the protected person; and second, whether a PPO was necessary for the protection or personal safety of the protected person.
The court accepted that there was an argument between the respondent and C on 29 October 2025, arising from the respondent’s insistence that C tidy up. However, the court’s findings turned on the evidential quality and the nature of the conduct. The court found C’s account credible and accepted that the respondent raised his voice and told C to leave the house, following C’s refusal to continue tidying. At the same time, the court concluded that the second incident relied upon by the applicant (alleged aggressive behaviour on 26 November 2025) was not established on the evidence in a way that amounted to emotional or psychological abuse within the statutory meaning.
Ultimately, the court’s analysis emphasised that while the statutory definition of emotional or psychological abuse is broad, it remains a legal threshold rather than a mere label. The court relied on interpretive guidance from earlier PPO decisions, including XWB v XWC ([2025] SGFC 135), and on the legislative context provided in the Second Reading of the relevant amendment bill. The result was that the court did not find sufficient basis to grant the PPO on the evidence presented.
What Were the Facts of This Case?
The respondent, XZV, was an 80-year-old man and the paternal grandfather of C, who was turning 15 in the relevant year. The respondent and his wife (C’s paternal grandmother) had been living with the family since C was born. They played an active caregiving role because both of C’s parents were working. The applicant, XZU, was C’s mother’s spouse’s parent’s daughter-in-law—more simply, the daughter-in-law of the respondent and the mother of C. The applicant and the respondent’s son were involved in ongoing divorce proceedings.
Within this household setting, the applicant commenced the PPO application in November 2025. In her application form, she sought a PPO on behalf of C based on a single incident alleged to have occurred on 29 October 2025. Notably, the application form did not raise any prior incidents. The applicant’s case therefore began with a narrow factual foundation: one incident, described as emotional and psychological abuse.
At the hearing, the evidential record was limited and controlled. The applicant filed a three-page document, but only the first page was admitted into evidence. At the mentions stage, the applicant confirmed that the other two pages contained evidence from third parties that she was not calling as witnesses and that those pages could be disregarded. The admitted document was marked as A1. The application form itself—containing the application details—was admitted and marked as A2. The respondent filed an 11-page affidavit, marked as R1.
The applicant called C as a witness. The court observed C to be comfortable in court and assessed her demeanour as forthcoming and consistent. The respondent’s counsel cross-examined C with sensitivity, including suggesting breaks when C showed slight signs of discomfort. The cross-examination was described as fair and reasonable, and the court did not perceive any undue confrontational approach.
What Were the Key Legal Issues?
The court identified two issues. First, it had to determine whether family violence had been committed or was likely to be committed by the respondent against C. Second, if family violence was established (or likely), the court had to decide whether it was necessary to issue a PPO for the protection or personal safety of C.
Because the application was framed as “emotional and psychological abuse”, the first issue required the court to interpret and apply the statutory definition of that category of abuse. The court had to determine whether the respondent’s conduct—particularly the alleged raising of voice, reprimanding, and telling C to leave the house—crossed the threshold from ordinary household discipline or conflict into conduct that “torments, intimidates, harasses or distresses” C, or causes (or is reasonably expected to cause) “mental harm” as contemplated by the Women’s Charter.
The second issue required a further assessment of necessity. Even if the court accepted that the respondent’s conduct was improper, it still had to consider whether a PPO was necessary for C’s protection or personal safety. This necessity inquiry is distinct from the existence of family violence; it requires the court to consider the protective function of the order in the context of the evidence and the relationship between the parties.
How Did the Court Analyse the Issues?
The court began by setting out the legal requirements for a PPO. Applications were brought under section 60 of the Women’s Charter 1961, which introduced the family violence regime effective 2 January 2025. Section 60A(1) provides that the court may make a protection order restraining a respondent from committing family violence against a family member if the court is satisfied on a balance of probabilities that the respondent has committed or is likely to commit family violence against the family member, and that the protection order is necessary for the protection or personal safety of the family member. The applicant bears the burden of proof.
In defining “family violence”, the court referred to sections 58B(2), 58B(3) and 58B(4) of the Charter. Emotional or psychological abuse is defined as conduct or behaviour that torments, intimidates, harasses or distresses a person, or causes or may reasonably be expected to cause mental harm to a person, including thoughts of suicide or self-harm. The court also noted that abuse may take the form of a single instance or a course of conduct, and that the conduct need not be directed at the family member in question so long as it is capable of being seen, heard or otherwise perceived by that family member.
Turning to the factual analysis, the court first addressed the incident on 29 October 2025, which was the only incident pleaded in the application form when the application was commenced. It was common ground that there was an argument between the respondent and C connected to the respondent’s desire that C tidy up some mess. The key dispute concerned the sequence of events—particularly when C shouted back and whether she used the words “this is my house, not your house”.
The court accepted C’s version of events. It relied on its assessment of C’s testimony as forthcoming, consistent, and not embellished. Importantly, C agreed to two points that were detrimental to her case during cross-examination: first, that the respondent’s actions were essentially discipline because he did not want his wife to clean up the mess for C; and second, that she had the courage to speak back to the respondent by defending herself with the statement that it was not his house. These concessions did not undermine the court’s overall acceptance of C’s narrative; rather, they demonstrated that C was not exaggerating and was willing to acknowledge aspects of the incident that did not favour her.
By contrast, the respondent’s oral evidence was inconsistent with his affidavit. The court highlighted “glaring” inconsistencies on two points: the respondent testified in court that he did not ask C to get out of the house and did not raise his voice, whereas his affidavit averred that he did raise his voice and asked C to get out at some point. The court acknowledged that memory lapses could occur given the respondent’s age, and it did not necessarily treat the inconsistency as dishonesty. However, it concluded that the inconsistencies made the respondent’s testimony less reliable, and therefore it preferred the applicant’s evidence on the incident’s core facts.
On the second incident, alleged to have occurred on 26 November 2025, the court noted that this allegation was raised after the filing of the application document A1. The applicant alleged that the respondent behaved aggressively at lunch by slamming a cup onto the table, forcefully placing items on the table, and staring at C. The respondent denied the staring and explained that as an 80-year-old, he sometimes drops things and had difficulty holding hot plates. The court observed that the respondent’s explanation was not challenged during cross-examination, and it found the explanation reasonable. It also noted that C testified the respondent did not directly engage with her on that occasion.
Having established the factual findings, the court then addressed the legal characterisation of the conduct as “emotional or psychological abuse”. It treated XWB v XWC ([2025] SGFC 135) as instructive for interpreting emotional or psychological abuse. In XWB, the court had observed that despite the statutory definition, what constitutes emotional or psychological abuse remains subjective and can be interpreted broadly. The risk of an overly liberal interpretation was emphasised as potentially inconsistent with legislative intent. The court in XWB had also referred to the Second Reading of the Women’s Charter (Family Violence and other Matters) (Amendment) Bill, where examples of emotional or psychological abuse included threatening to withhold monthly allowances, constantly monitoring a victim’s whereabouts, and other conduct of a similar coercive or harmful character.
Applying these principles, the court’s approach was to distinguish between conduct that is merely unpleasant or part of family conflict, and conduct that is capable of causing mental harm or that torments, intimidates, harasses or distresses in the statutory sense. While the court accepted that the respondent raised his voice and told C to leave the house during the 29 October incident, it still had to decide whether that conduct, on the evidence, met the threshold of emotional or psychological abuse and whether it justified a PPO. The court’s reasoning reflected that a PPO is a protective legal mechanism, not a remedy for every domestic disagreement. The court therefore required a careful link between the conduct proven and the statutory concept of emotional or psychological abuse.
On the evidence, the court found that the second incident did not add sufficient weight to the applicant’s case. The respondent’s explanation was reasonable, unchallenged, and supported by the lack of direct engagement with C. The court’s analysis thus focused on whether the single incident on 29 October 2025, as accepted, was enough to satisfy the statutory threshold and the necessity requirement for a PPO.
What Was the Outcome?
After applying the two-stage test under section 60A(1) of the Women’s Charter, the court did not grant the PPO. While the court accepted C’s account of the 29 October 2025 incident and found the respondent’s evidence less reliable due to inconsistencies, it concluded that the evidence did not establish family violence to the requisite standard—particularly in relation to emotional or psychological abuse as defined in the Charter.
Practically, the dismissal meant that C remained without the protective restrictions that a PPO would have imposed on the respondent. The court’s decision underscores that even where a child’s testimony is accepted on key facts, the applicant must still prove that the proven conduct amounts to “family violence” under the statutory definition and that a PPO is necessary for personal safety or protection.
Why Does This Case Matter?
XZU v XZV is significant for practitioners because it illustrates how Family Court judges apply the post-2 January 2025 PPO regime in the Women’s Charter, particularly the threshold for emotional or psychological abuse. The decision reinforces that the statutory definition is broad, but not boundless. Courts will still require a principled assessment of whether the proven conduct is capable of causing mental harm or meets the legislative examples and policy rationale behind the amendment.
The case also demonstrates the importance of evidential discipline in PPO applications. The applicant’s evidence was limited: only part of A1 was admitted, third-party material was not called, and the second incident was introduced after the initial filing. While the court did not disregard the later incident solely for timing, it assessed its evidential strength and found the respondent’s explanation reasonable and unchallenged. For lawyers, this highlights that PPO applications are fact-sensitive and that cross-examination strategy and evidential completeness can materially affect outcomes.
Finally, the decision provides guidance on credibility assessment in sensitive child testimony. The court’s observations about C’s demeanour, consistency, and willingness to concede points detrimental to her case show that credibility findings can be decisive. However, credibility alone is not sufficient; the court must still connect the accepted facts to the legal elements of family violence and necessity. This dual requirement—fact proof and legal characterisation—should guide how counsel frames allegations, structures evidence, and addresses the statutory threshold.
Legislation Referenced
- Women’s Charter 1961 (Singapore) — Section 60
- Women’s Charter 1961 (Singapore) — Section 60A(1)
- Women’s Charter 1961 (Singapore) — Section 58B(2), 58B(3), 58B(4)
- Women’s Charter 1961 (Singapore) — Section 58B(5)
- Women’s Charter 1961 (Singapore) — Section 58B(6)
Cases Cited
- [2024] SGFC 1
- [2024] SGFC 103
- [2025] SGFC 135
- [2025] SGFC 59
- [2026] SGFC 31
- [2026] SGFC 8
Source Documents
This article analyses [2026] SGFC 31 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the full judgment for the Court's complete reasoning.