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In the FAMILY JUSTICE courts of the republic of singapore
[2025] SGFC 123
FC/OADV 468/2025
Between
XUL
… Applicant
And
XUM
… Respondent
judgement
Family Law – Relocation – Child – Whether permission should be granted for a 12-year-old child to be relocated to the United Kingdom to attend a boarding school while both parents continue to reside in Singapore – Framework for assessing relocation applications
This judgment is subject to final editorial corrections approved by the court and/or redaction pursuant to the publisher’s duty in compliance with the law, for publication in LawNet and/or the Singapore Law Reports.
XUL
v
XUM
[2025] SGFC 123
Family Court – FC/OADV 468 of 2025
District Judge Kow Keng Siong 17 October and 17 November 2025
17 November 2025
District Judge Kow Keng Siong:
Introduction
1 This case concerns a mother’s application to relocate her 12-year-old son from Singapore to the United Kingdom (“UK”). Two features make this application unusual. First, unlike the typical relocation case, the applicant-mother will not reside with the son in the UK. Instead, she intends for him to reside at an English boarding school while she remains in Singapore. Second, she contends that the idea of boarding originated from the child.
2 The father opposes the application on two bases. First, a 12-year-old would not, on his own, propose attending an English boarding school. Second, the child is not sufficiently mature to understand the implications of living overseas without his parents.
Foot Note 1
Respondent’s Written Submissions dated 09.10.25 at [38] to [43].
3 When a parent seeks to relocate a child from Singapore, the court’s overriding concern is the child’s welfare and best interests: BNS v BNT [2015] 3 SLR 973 (“BNS”) at [19]. Applying this principle, the question here is whether it will serve the 12-year-old’s welfare and best interests to relocate him to the UK to attend a boarding school while his parents remain in Singapore.
Background
4 The applicant-mother (“Mother”) and respondent-father (“Father”) are divorced. Their son was born in November 2013 (“Son”). Since 2022, the Mother has been the care-parent, while the Father has weekend access.
5 According to the Mother, the Son expressed, in early 2024, a desire to pursue secondary education abroad. She took his aspirations seriously: she conducted the relevant research, engaged educational specialists, and visited potential schools. She believes that she can fund the boarding education on her own.
Foot Note 2
Written Submissions for Applicant Mother dated 09.10.25 at [44], [45] and [60] to [64].
6 In September 2024, the Mother presented the overseas-study proposal to the Father. He opposed it.
7 In April 2025, an English boarding school (“School”) indicated that it could enrol the Son for the January 2026 intake, subject to the Father’s consent. The Father maintained his objection, thus resulting in the present application.
Applicable principles
Overriding consideration
8 As noted, the overriding consideration in relocation applications is the child’s welfare and best interests. This is the lens through which every other consideration is assessed. The assessment is an objective one. It eschews (a) any “pre-fixed precedence or hierarchy” among factors, (b) categorical pigeonholes that predetermine outcomes, and (c) presumption for or against relocation: BNS at [20] to [22]; WRU v WRT [2024] SGHCF 23 (“WRU”) at [18]; UYK v UYK[2020] 5 SLR 772 (“UYK”) at [38]; TAA v TAB[2015] 2 SLR 879 (“TAA”) at [17]. Thus, neither a parent’s good intentions nor a child’s strong desire to live abroad is determinative. These are simply factors to be weighed against others in assessing whether relocation should be permitted.
Analytical framework
9 What factors are relevant, and how do courts determine whether relocation serves a child’s welfare and best interests? The case law provides the following guidance.
Reasons for relocation
10 The court first examines the reasons advanced for relocation, assessing whether they are genuine, rational, and coherent:TAA at [25] to [27]; UXH v UXI [2019] SGHCF 24 (“UXH”) at [23]; UYK at [67] and [69]; Liew Kah Heng v Kwok Fong Ee [2000] SGDC 7 at [18] and [19]. In general, applications aimed at diminishing the child’s relationship with the access-parent will be rejected: BNT v BNS [2014] 4 SLR 859 (“BNT”) at [51] and [53]; Re C (an infant) [2003] 1 SLR(R) 502 (“Re C”) at [22].
Impact of relocation on the child
11 Next, the court considers the impact of relocation on the child: Re C at [17(a)]; Wong Phila Mae v Shaw Harold [1991] 1 SLR(R) 680 at [26] and [27]; VZJ v VZK [2024] SGHCF 16 at [9] and [10]; VTU v VTV [2022] 3 SLR 598 at [13].
12 In assessing such impact, the court considers, among others –
(a) The extent of the child’s integration in Singapore and his or her ability to adapt to change.
(i) For instance, relocation may be less disruptive for a child accustomed to moving with expatriate parents than for a child who has lived here since birth with Singaporean parents. Further, what may be manageable for a mature teenager can feel very different to a child in early adolescence.
(ii) Apart from age, the court will also consider the child’s (1) personality, (2) physical, emotional, and educational needs, and (3) each parent’s capacity to meet those needs if relocation is granted.
(b) The strength of the child’s attachment to his or her parents and other caregivers. TSF v TSE [2018] 2 SLR 833 at [51] and [52]; UXH at [28].
(i) Distance can strain even the strongest of bonds. The court will scrutinise the applicant-parent’s willingness to sustain the child’s relationship with the respondent-parent.
(ii) A history of cooperation between the parents may give confidence that contact will be facilitated. On the other hand, a pattern of high conflict points the other way and may call for the applicant-parent to provide clearer safeguards if relocation is to be allowed.
(c) Whether the applicant-parent has concrete plans to minimise the disruptions caused by relocation.
The court will assess whether the post-relocation environment will be stable or uncertain. Specifics matter. Vague, speculative, or hastily made unilateral plans are likely to count against relocation: WRU at [37]; TAA at [20].
The child’s views
13 The child’s views are also important part. The weight to be accorded to such views depends on (a) the child’s age and maturity, (b) whether the views are supported by reasons, (c) whether the views have been held for a long time or a transient, (d) whether the child has been influenced or coached, and (e) whether the child understands the implications of the relocation: see e.g., WKM v WKN [2024] 1 SLR 158 (“WKM”) at [45(a)]; AZB v AZC [2016] SGHCF 1 at [15] and [25]; ZO v ZP [2011] 3 SLR 647 at [15] and [16]; s 125(2)(b) of the Women’s Charter 1961.
Burden and standard of proof
14 After considering all relevant factors, the court will then evaluate the two options: (a) permit relocation, or (b) maintain the status quo in Singapore. This evaluation involves two steps: first, identify the benefits and harms of each option; second, compare the options to determine which one better serves the child’s welfare and best interests in both the short and longer term.
15 The parent seeking to uproot a child from a settled living arrangement bears the burden of proof. That parent must show, on a balance of probabilities, that the child’s overall welfare is better served by relocation than by remaining in Singapore. The question is not merely whether relocation offers advantages, but whether – taken as a whole – it is the better path for the child.
16 In assessing whether this burden is met, several points bear emphasis.
(a) The assessment is forward-looking: it considers not only what the child presently enjoys, but also what he or she stands to gain – or lose – by relocation.
(b) Given the high stakes, the court will proceed with care. For instance –
(i) Where the potential advantages are speculative and the risks of emotional or developmental harm are substantial, the proper course may be to remain in Singapore. This is especially so for younger, well-settled children.
(ii) Where benefits and downsides are finely balanced, one option may be to defer relocation to a later stage.
(c) Caution, however, does not equate to a default rule against relocation. Major changes to improve the quality and prospects of life will entail risk and uncertainty. What a court seeks to do is to avoid exposing the child to a level of risk from relocation that is unreasonably high when compared to (i) its potential gains and (ii) the risk from remaining in Singapore.
My decision
17 I will now apply the above framework – grounded in the child’s welfare and interests – to the facts of this case.
Reasons for relocation
18 The Mother believes that the School is aligned to the Son’s strengths and will develop his potential.
Foot Note 3
Written Submissions for Applicant Mother dated 09.10.25 at [37] to [40].
She highlights that it has (a) a strong academic reputation, (b) wide co-curricular offerings that emphasise critical thinking, creativity, and leadership, and (c) won awards such as Co-Educational Independent School of the Year and Best Sports School in the UK.
Impact of relocation on the Son
Nature and extent of impact
19 The Father, on the other hand, is concerned that the Son (a) is “far too young” to live overseas without a resident parent, (b) is not mature enough to cope with homesickness as well as social and academic pressures, and (c) may face challenges in re-integrating into Singapore in the future, including National Service.
Foot Note 4
Respondent’s Written Submissions dated 09.10.25 at [3], [26] to [31]; Written Submissions for Applicant Mother dated 09.10.25 at [18], [20], [26], [51], [73] and [74].
The Mother’s mitigation plan
20 The Mother contends that the Father’s concerns are “speculative”: She had (a) engaged an educational consultant, (b) visited the School,
Foot Note 5
Written Submissions for Applicant Mother dated 09.10.25 at [14], [42], [51] and [60].
and (c) chosen it because of its emphasis on pastoral care.
Foot Note 6
Written Submissions for Applicant Mother dated 09.10.25 at [41], [43] and [47].
21 In any event, to mitigate possible adjustment issues, she plans to (a) be in the UK during the first six months of the school term, (b) visit the Son regularly thereafter, (c) maintain frequent video, messaging, and phone contact, and (d) arrange for the child to return to Singapore during school holidays.
Foot Note 7
Written Submissions for Applicant Mother dated 09.10.25 at [26], [28], [50].
The Son’s views
22 I now come to the Son’s views. There is a dispute as to whether the boarding idea originated with him. To address this, I spoke with the child in chambers with a Court Family Specialist present.
23 Based on that conversation, I am satisfied the idea did originate from the child. He said that it arose after watching a TikTok video about the School. He spoke enthusiastically about its campus, facilities, and co-curricular opportunities. I accept that his wish is genuine and is not the product of coaching or pressure.
24 Although the Son is keen to enrol in the School, I am unable to give it full weight. This is because he appears to lack the maturity to fully comprehend and manage the consequences of relocation. During my conversation with him, he held an unrealistically rosy view of boarding, saw virtually no downsides to the experience, and proposed simplistic coping strategies for homesickness, peer conflict, and academic pressure.
25 In summary, while the Son genuinely wishes to enrol at the School, he has not fully grasped the challenges of boarding. His cognitive and critical-thinking skills are still developing. This is unsurprising as he is only 12.
Weighing the two options
26 I now weigh the benefits and harms of the two options: permitting relocation (“Option A”) or the Son remaining in Singapore (“Option B”).
Option A
27 I begin with Option A.
28 I accept that the School is reputable and can offer the Son significant educational opportunities and international exposure. Boarding can also cultivate his independence and character.
Foot Note 8
Written Submissions for Applicant Mother dated 09.10.25 at [72]; Respondent’s Written Submissions dated 09.10.25 at [26].
29 However, the potential downsides are serious and, in my view, outweigh the benefits. Let me explain.
(a) Relocation typically entails (i) emotional strain (homesickness, anxiety), (ii) educational disruption (adjusting to a different system and challenges of eventual re-entry to the Singapore education system), (iii) social upheaval (leaving behind established relationships and building new ones), and (iv) other concerns (safety and stability of living arrangements).
(b) In the present case, the impact of relocation is likely to be magnified due to the following.
(i) At 12, the Son is in early adolescence – a period of heightened emotional and psychological flux. Children at this age generally seek independence while at the same time rely heavily on physically present caregivers to buffer stress.
(ii) The evidence shows that the Son (1) is closely attached to the Mother, (2) has limited experience in independently managing his wellbeing in Singapore, and (3) has travelled outside Asia only once (to visit the School and to France on the same trip). The child will face difficulties in communicating his adjustment issues to his loved ones in Singapore given the distance and time-zone differences.
(iii) Further, the enrolment is proposed to take place in less than two months (January 2026). Such a sudden and substantial reduction in emotional support will increase the Son’s vulnerability to anxiety, loneliness, and adjustment difficulties. This is not a small step but a leap – to a new country, culture, independent living, and roommates. The absence of a resident parent in a boarding environment heightens the risk of the child’s emotional difficulties being undetected and unaddressed.
30 Because neither parent would reside with the Son in the UK for a substantial period, I must scrutinise the Mother’s mitigation plan more closely. In this regard, she has failed to satisfy me that it adequately addresses the above concerns.
(a) Her plan relies heavily – after an initial six-month stay – on the School’s pastoral system and the child’s self-reporting. There is no detail on how early emotional or behavioural warning signs will be identified, escalated, and addressed if he struggles. Neither is there evidence of the School’s protocols to handle bullying.
(b) In my view, the Mother’s proposal for regular virtual contact underestimates practical constraints of time zones and school schedules. While digital platforms help, they cannot substitute the warmth and immediacy of physical presence, especially for younger children. As observed in BNT at [35(c)] –
The facts of the children’s young ages and the difference in time zones between Canada and Singapore will make it difficult for their father to sustain the closeness of his present relationship with them. With younger children, closeness is promoted by physical contact and frequent interaction in routine activities. Telephone and internet access are frequently unsatisfactory due to technical difficulties and generally permit only one type of interaction: conversation. Normal family life consists of much more than conversations between parent and child – there are joint activities, routines, projects, discipline and learning from the examples set by the parents in all sorts of situations.
(c) There is also a real possibility that boarding may prove too much for the Son. A premature return to Singapore could bring further risks: (i) re-adjustment to the local syllabus, (ii) the burden of perceived “failure”, and (iii) guilt over having wasted funds and time – an onerous burden for a young child. The Mother has not dealt with these issues in her evidence.
(d) Instead, she submits that the Son is resilient and will adapt. As in XBF v XBE [2024] SGHCF 42 at [16], I see no reason to test his resilience through a high impact move. There is no pressing need for boarding now – overseas education can still be considered when he is older.
31 At the hearing, the Mother’s counsel, for the first time, suggested that she might relocate to the UK so the Son would not be without a resident parent, and that this could be imposed as a condition for allowing the application. In my view, it is not appropriate to decide in favour of relocation based on this late oral suggestion.
(a) First, the Mother had ample opportunity to run this suggestion as her primary case. She did not. Instead, her evidence proceeded on the basis that she would return to Singapore after six months, leaving the Son in the UK. Her financial and logistical planning reflects that premise.
(b) Second, the suggestion lacks details. For instance, the Mother did not explain how she would obtain permission to work in the UK, how she would support herself and the Son, and how long such an arrangement could be sustained.
(c) Third, if the suggestion were to be given serious consideration, this would likely require fresh evidence from the Mother. This would prejudice the Father and prolong uncertainty for the Son.
32 For completeness, although not requested by the Mother, I have considered adjourning the matter to allow her to formulate a detailed plan to relocate with the Son. I eventually declined to do so.
(a) First, the School’s intake is imminent – less than two months away. An adjournment would lead to hurried proposals on life-shaping decisions. It would also create acute stress and uncertainty about the child’s immediate living and schooling arrangements.
(b) Second, if, in future, the Mother develops a concrete plan to relocate with the child, she remains free to file a fresh application.
Option B
33 Next, I turn to Option B. This option preserves a stable home environment. From my conversation with the Son, it is evident that he has strong connections with the Mother and paternal grandparents.
34 The potential downsides are that the child may view dismissal of the application as extinguishing his aspirations, feel frustrated, and blame the Father. These downsides are less serious than the risks under Option A. They can also be mitigated – he may revisit overseas education later, when he is more mature.
35 For completeness, there is no evidence that (a) the child has needs that cannot be met by Singapore’s education system, or (b) the current arrangements are incompatible with his welfare and best interests.
Conclusion
36 The balance tips in favour of Option B.
(a) In my view, the risks to the Son under Option A are unreasonably higher than its benefits. While relocation offers educational and experiential upside, at this stage, it does not outweigh the significant risks to his emotional security and developmental need for day-to-day parental presence.
(b) The downsides of Option B are manageable. On a holistic assessment, the child is more likely to suffer greater harm under Option A than Option B.
37 As the Mother has failed to show, on a balance of probabilities, that the Son’s overall welfare is better served by relocation than by remaining in Singapore, I dismiss the application.
Final observations
38 Before concluding, I have some observations for the parties.
To the parents
(a) Both of you are trying, in your own ways, to do what you believe is best for your son. You share the same goal but differ in approach: one emphasises opportunity and early independence; the other, stability and certainty. This decision is not a judgment on your parenting philosophies. Neither does it suggest that your child is undeserving of overseas education, nor that boarding is inherently unsuitable. It reflects only my assessment that such an experience is presently not in his welfare and best interests.
To the Mother and the Son
(b) I understand your disappointment. The Mother has invested time and resources to find a suitable school. The Son looked forward to a unique experience. This decision does not close the door to overseas education. The question can be revisited when the child is older and more mature. For now, the safer course is for him to remain in Singapore, with both parents playing prominent roles in his life – rather than appearing only as images on a screen from afar.
Kow Keng Siong District Judge
Amy Lim Chiew Hong (M/s Amy Lim Law Practice) for the Mother;
Alain Abraham Johns & Emira binte Abdul Razakjr (M/s Alain A Johns Partnership) for the Father.
This judgment text has undergone conversion so that it is mobile and web-friendly. This may have created formatting or alignment issues. Please refer to the PDF copy for a print-friendly version.