1. This is an appeal against interim orders for parenting time made on 7 July 2026.

2. The parties are Italian nationals and are working in Singapore. The Mother works as an academic in a local university and the Father works in a research and technologies company. They married on 22 July 2020 in Rome and are presently undergoing court proceedings in Italy for legal separation and divorce. They have one child born to the marriage who is the subject matter of these proceedings (the “Child”). The Child was born on 5 July 2021 in Singapore and is 5 years old as of the date of these grounds. The Child was born with an extensive port wine stain and has been investigated for suspected Sturge-Weber syndrome for which he has undergone laser treatment and remains under specialist follow-up.

3. OAG 37/2026 is the Mother’s application filed on 27 February 2026 under the Guardianship of Infants Act 1953 (the “GIA”) for, inter alia, joint custody with care and control granted to her and specified access to be granted to the Father.

4. OAG 68/2026 is the Father’s cross-application filed on 23 April 2026 under the GIA for, inter alia, joint custody with care and control granted to him and supervised access to be granted to the Mother. The Father also sought orders for the Mother to undergo a psychiatric and/or psychological evaluation.

5. Both parties have also prayed for a myriad of other orders including in relation to the retention of the Child’s official documents in their respective applications.

6. On 4 March 2026, an interim order was recorded by consent at a case conference before the learned District Judge Nicole Loh which set out, inter alia, that (1) parties were restrained from taking the Child out of Singapore; and (2) the Child’s passport was to be held by the Father’s counsel (the “4 March Consent Order”).

7. I heard the above applications together with the three interlocutory applications that parties had filed on 24 June 2026. The decision in relation to the interlocutory applications which pertained to the parties’ respective applications to strike out evidence as well as the Father’s application to admit a further affidavit was separately issued via Registrar’s Notice on 14 July 2026.

8. After hearing the parties on 24 June 2026, I adjourned the matter for a case conference on 7 July 2026 as I had indicated to parties that I wished to appoint a custody evaluator so that a report could be furnished to the court. The adjournment was granted for the purposes of parties approaching professionals in the private sector who would be able to provide such a service.

9. Apart from recording an order by consent that the parties were to have joint custody of the Child, I also made the following interim orders at the hearing on 24 June 2026 pending further orders to be made in the proceedings that:

(a) The Mother shall have time with the Child as follows:

10. At the case conference on 7 July 2026 before me, I made orders pertaining to the appointment of the custody evaluator and to give effect to the overnight access order I had made on 24 June 2026. For the avoidance of doubt, I had also ordered that all other orders in the Order of Court dated 24 June 2026 were to stand.

11. The Father has now appealed against part of the orders I had made on 7 July 2026. The specific orders that the Father is appealing against (as set out in the Notice of Appeal filed on 21 July 2026) are the following:

(i)  Tuesdays from after school at 1pm to 8pm;

(ii) Thursdays from after school at 1pm to 8pm;

(iii) Fridays from after school at 1pm to Saturday 8pm.”

12. The objective of the orders made on 7 July 2026 was to give effect to the overnight access order made on 24 June 2026 (for which no appeal was pursued by the Father). It is unclear to me as to whether the Father is appealing against the way the overnight access orders have been effected by way of my orders made on 7 July 2026. In any event, I will set out my reasons for making the interim orders I have made on 24 June 2026 for the Mother to have unsupervised parenting time with the Child and why I have made orders for her to have one night each week of overnight access from Friday after school to Saturday at 8pm by way of my orders made on 7 July 2026 as these orders are inter-related. These interim orders are in place until such time that the Court issues the final decision for the cross-OAG proceedings, which will follow the completion of the private custody evaluation.

13. In the course of these proceedings, the Mother has filed a total of four affidavits and thirteen witness affidavits. The Father has filed one affidavit and ten witness affidavits. Where necessary, I have also referred to the affidavits that have been filed by the parties in the three interlocutory applications.

14. It is undisputed that from the point of the Child’s birth up until 5 November 2025, the Child was residing with both parents with the latest residence being a rented condominium unit in the central part of Singapore (the “Rental Unit”).

15. On 5 November 2025, the Father moved out of the Rental Unit together with the Child and the domestic helper. This was a unilateral act on the part of the Father without any order of court. No prior notice furnished to the Mother nor was consent obtained from the Mother. The Mother was notified of the Father’s actions only later in the day on 5 November 2025 when the Father’s solicitors wrote to the Mother to notify her of the same. ¹

16. Post 5 November 2025 until the orders made on 24 June 2026, the Mother’s time with the Child was supervised by the Father and it usually took place at the playground of his residence on Tuesdays, Thursdays and Saturdays from 6pm to 7.30pm as well as a fifteen-minute telephone call on Sundays. This arrangement was again unilaterally imposed by the Father without any order of court.

17. The Father submits that supervised access is necessary to protect the Child from what he characterises as the Mother’s persistent pattern of emotional dysregulation, poor judgement and inability to prioritise the Child’s welfare above her own objectives. He advances three principal grounds in support of his position.

18. First, the Father relies on a series of incidents during access sessions and handovers which he submits demonstrate the Mother’s emotional volatility and inability to regulate her own conduct in the Child’s presence. ² He relies, among others, on the following incidents of significance: (i) the events of 29 November 2025, when the Mother attempted to remove the Child from his school recital without his shoes or water bottle; (ii) the events of 6 December 2025, when the Mother made comments designed to frighten the Child, causing him to become distressed and beg to return to the Father; (iii) the events of 19 March 2026 when the Mother confronted the Father’s helper outside school, forcibly grabbed the Child and caused him to become hysterical; the incident of 3 April 2026, when the Child sustained a minor injury while in the Mother’s care; and (iv) the events of 6 May 2026, when the Mother used the promise of a toy to bring the Child to her condominium, instructed security personnel not to permit the Father entry, and the Mother’s mother repeatedly struck the Father with an umbrella in the Child’s presence, causing the Child to become terrified and repeatedly call for the Father. The Father also relies on audio and video recordings which he submits capture the Mother’s emotional volatility, including a recording in which the Mother, while the Child was visibly distressed and crying, told him, “You don’t need me, you need Paw Patrol” and directed him away from her rather than attempting to comfort him.

19. Secondly, the Father relies on concerns regarding the Mother’s mental health. He submits that the Mother was simultaneously engaged with multiple mental health practitioners, including having undergone 24 sessions at Adelphi Psychiatry within a five-month period that she did not disclose to the Court. ³ He argues that the medical report produced by the Mother (which she claims support her case that she had no mental health concerns) was based on a total of approximately two hours of contact across three sessions, and is insufficient to provide a reliable assessment of the Mother’s psychological functioning, emotional regulation and parenting capacity, and that the Court should not place determinative weight on it at this stage. ⁴ He submits that the undisclosed extent of the Mother’s engagement with other mental health services is itself a matter of concern that warrants further independent investigation before unsupervised access is permitted.

20. Thirdly, the Father submits that the Mother presents a flight risk and that supervision is necessary to protect against the risk of the Child being removed from Singapore. ⁵ He relies on the Mother’s commencement of civil proceedings in Italy in which he alleges she falsely represented to the Italian court that the Child was habitually resident in Rome and that the Father had wrongfully removed him from Italy. He further relies on the Mother’s subsequent engagement with the Italian Embassy in Singapore to explore diplomatic avenues for the Child’s return to Italy, and on a comment made by the Mother to the Child on 6 April 2026 that “as soon as we have your passport, we will bring you to a wonderful place”. The Father submits that these matters, taken together, demonstrate that the Mother cannot be trusted to exercise unsupervised parenting time without posing a risk of unilateral removal of the Child from the jurisdiction.

21. The Father accordingly seeks an order that the Mother’s access be supervised through a Divorce Support Specialist Agency or Supervised Visitation Programme, and that overnight access be deferred until the completion of an independent psychiatric assessment of the Mother or until the Child attains the age of seven years, whichever is earlier.

22. The Mother submits that supervised access is one of the most serious restrictions available in family proceedings, ordinarily reserved for situations where there is credible evidence that a parent presents a genuine risk to a child’s safety or welfare. She argues that no such evidence exists in the present case.

23. The Mother’s central submission is that the Father’s principal justification for supervision – her alleged mental ill health – has been independently assessed by a qualified professional and found to be unsupported. She relies on the evidence of Dr John Bosco Lee, a consultant psychiatrist accredited by the Ministry of Health, who assessed her over three clinical sessions, interviewed five other friends, and concluded that there is no evidence of mental illness, that her relationship with the Child is good, and that she is fully competent and able to care for him. She submits that this constitutes the only independent professional evidence before the Court on the question of her mental health, and that it does not support the imposition of supervised access.

24. The Mother further submits that the supervised access arrangements currently in place were never sanctioned by any court order. They were unilaterally imposed by the Father following his removal of the Child on 5 November 2025, at a time when both parents held equal parental rights. She argues that the Father had no legal authority to dictate the frequency timing, venue, conditions of her contact with her own son, and that the Court should attach little weight to the act that such arrangements have persisted since November 2025, as their continuation reflects unilateral action rather than any judicial determination of the Child’s best interests.

25. The Mother also relies on the objective evidence of the Child’s welfare and development during the period prior to 5 November 2025. She submits that not a single teacher, medical professional, school representative or other independent adult raised any concern about the Child’s welfare or development during that period, and that the Child is described by multiple independent witnesses as having been a happy, affectionate and well-adjusted child. She argues that this objective picture is wholly inconsistent with the suggestion that her unsupervised care presents a risk to the Child.

26. The Mother further argues that the present access conditions are themselves harmful to the Child. She submits that access has been conducted at an unsheltered outdoor poolside playground regardless of weather conditions, including during heavy rain and strong winds, notwithstanding the Child’s ongoing medical needs arising from his laser treatment, which requires protection from sun exposure. She argues that the Father’s insistence on this venue is itself inconsistent with his professed concern for the Child’s welfare.

27. The Mother additionally submits that the Father’s practice of recording her during her interactions with the Child, and the involvement of the paternal grandfather in monitoring and shadowing her interactions with the Child, creates an oppressive atmosphere of surveillance that is inconsistent with fostering a natural and meaningful parent-child relationship. She argues that a young child should not experience parental time as a monitored event, and that such conduct is inconsistent with the Father’s professed support for the Child’s relationship with her.

28. Finally, the Mother relies on the authority of XCQ v XCP [2025] SGHCF 26, where Choo Han Teck J held that restrictive access conditions should not be imposed in the absence of clear evidence, as such conditions risks entrenching acrimony between the parties. She submits that the evidence before the Court does not meet that threshold, and that the prayer for supervised access should accordingly be refused.

29. The starting point of any discussion on the applicable legal principles would be the GIA. Section 5 of the GIA allows the Court to make orders relating to the custody and care of infants, and section 3 of the GIA directs that the Court consider the child’s welfare as its first and paramount consideration.

30. In terms of the circumstances where supervised access would be considered appropriate, the past cases have made it clear that this would generally involve situations where there is a risk of abuse or danger to the child, estrangement between parent and child, or factors making unsupervised access difficult to implement.

31. There has been much said by the Father regarding what he characterises as falsehoods perpetuated by the Mother in the Italian court proceedings, which he submits goes towards her credibility and affects the weight that this Court should accord to her evidence. To be clear, in reaching my findings and making orders, I have looked at the objective evidence where available.

32. The Father had engaged in extensive recording of the Mother and raises concerns regarding the Mother’s behaviour on these recordings. Having reviewed those recordings, while some show the Mother behaving in a hostile manner towards the domestic helper, none of them show the Mother behaving in a manner that was harmful towards the Child. There was only a single recording of the Mother being emotional and frustrated when the Child was crying ⁶ . This recording does not suggest that there is a need for the Court to intervene by supervising the Mother’s time with the Child. It would be impossible to expect any parent, even the most devoted, to respond with perfect composure to their child at all times – parenting is demanding and moments of imperfect responses are an inevitable part of it. The question is not whether a parent has fallen short of an ideal response on a given occasion, but whether the response presents real safety concerns for the Child. The Father makes much of the fact that the recording show the Mother failing to help regulate the Child's emotions, but one such instance of less than ideal parenting, which does not present any real safety concern for the Child, is not sufficient for me to conclude that the Mother's time with the Child ought to be supervised.

33. The Father also relies on WhatsApp messages sent to the Mother on 9 March 2025, 29 May 2025 and 31 August 2025, in which he informed her that her conduct harmful to the Child. Based on a review of the messages, the conduct referred to appears to relate to instances where the Mother has made certain statements in front of the Child and insisted on changing his bedtime routine. Again, I did not consider these instances of such a grievous nature that warranted the supervision of the Mother’s time with the Child post 5 November 2025.

34. There are also a number of incidents that have been referred to by the Father which arose after 5 November 2025. While I do not propose to address each incident individually, I observe that the Father’s insistence on supervising the Mother’s time with the Child - particularly in the immediate aftermath of his unilateral and unanticipated move out of the Rental Unit on 5 November 2025 - would not have created the conditions for a healthy co-parenting atmosphere, especially given that the relationship between them was already strained due to the marital breakdown. It is also undisputed that the Mother’s relationship with the Father’s domestic helper had broken down and appeared to be one of the factors that contributed to the marital breakdown namely the fact that he had continued to insist on retaining the domestic helper notwithstanding the Mother’s difficulties with her. As such, as I pointed out to the Father’s counsel during the hearing on 24 June 2026, it would not be altogether surprising that incidents may occur during access if the Father continues to insist on his presence, the presence of his family members or his helper – particularly against the backdrop of the events of 5 November 2025.

35. As for the Father’s assertions regarding the Mother’s mental health and his concerns about the medical report exhibited by the Mother, there is force in the observation that a brief clinical assessment cannot capture the full range of a parent’s conduct over an extended period. The question at this stage is whether the evidence before me establishes a sufficient level of risk to the Child to warrant supervision pending the Court's full decision. Having considered the Father's concerns carefully and taking them at their highest, I am not satisfied that they cross that threshold. These concerns are more appropriately addressed through the private custody evaluation that has been ordered, which will afford a far more comprehensive and nuanced assessment of both parents' functioning and parenting capacity.

36. As for the recordings referred to by the Father ⁷ which he says reveal a consistent pattern of emotional dysregulation, hostility and erratic behaviour on the part of the Mother - not even one of those recordings involved the Child. The extent of the Father's recording activity bears emphasis. This was not a case of a parent who, on one or two occasions, happened to capture an incident on his phone. The Father engaged in what can only be described as a systematic and sustained effort to document the Mother's conduct, deploying recording devices within the home (including recording the Mother’s session with her counsellor which was done in the privacy of the bedroom) and recording interactions over an extended period both before and after he moved out of the Rental Unit on 5 November 2025. The sheer volume and persistence of this recording activity means that the Father had ample opportunity to capture any instance of the Mother behaving in a manner that was harmful or dangerous towards the Child. That he has not produced a single such recording is, in my view, telling. If the Mother's conduct towards the Child was truly as alarming as the Father portrays it to be, one would expect that at least some of that conduct would have been captured in the course of such extensive surveillance. The absence of any such recording is not a neutral fact — it is a significant one. The episodes that were captured in those recordings were directed towards either the Father or the domestic helper, and whatever one makes of the Mother's conduct in those interactions, they do not speak to her conduct as a parent towards the Child.

37. The incidents that have occurred during access occurred under conditions of surveillance and monitoring which the Mother submits were provocative and oppressive. It is my considered view that such incidents will be significantly reduced once the presence of the Father, his family members and his helper is removed from the equation. In making the interim orders that I have, I have taken into account the fact that prior to 5 November 2025, the Mother had spent significant amounts of time with the Child on an unsupervised basis and had taken the Child out on her own. From 5 November 2025 to 24 June 2026 — a period of almost eight months — the Mother has been subject to supervised access. There is nothing in these circumstances to warrant the continued supervision of the Mother's time with the Child, which, as rightly observed by the Mother's counsel, is a measure ordinarily reserved for exceptional situations. I would add that the period of almost eight months during which the Mother was subjected to supervised access was, on the evidence before me, an excessive restriction.

38. Supervised access is a significant curtailment of a parent's relationship with their child and is not a measure to be imposed or maintained lightly. The prolonged imposition of supervised access in these circumstances appears not to have been based on any actual harmful conduct that the Mother has exhibited towards the Child. The effect of this on the Mother — and, more importantly, on the Child's relationship with her — should not be underestimated. For almost eight months, the Mother's time with the Child was confined to sessions of one and a half hours at the playground of the Father's residence. This severely deprived the Mother of the opportunity to take the Child out, to engage in activities with him, and to share with him the ordinary but irreplaceable experiences that form the fabric of a parent-child relationship — trips to the park, meals together, outings and the simple pleasures of spending unhurried time in each other's company. A child's bond with each parent is a living thing; it requires regular, meaningful and unencumbered contact to be nurtured and sustained. Eight months of supervised access, imposed without sufficient justification, is eight months during which that bond was unnecessarily constrained. It is precisely because of this prolonged and unjustified constraint that I have made interim orders for unsupervised parenting time. Every further day of unnecessary restriction is a day lost in the Child's relationship with the Mother — a relationship that, at this stage of the Child's development, is of profound importance.

39. As regards the Father’s reliance on the fact that the Mother was engaged with multiple mental health practitioners, including attending 24 sessions at Adelphi Psychiatry, the Mother has responded to explain that she was referred for psychotherapy and that she had attended a total of 14 psychotherapy sessions between 15 October 2024 and 15 July 2025, which were directed at managing her emotional distress arising from difficulties in her working relationship with the domestic helper and the resulting stress within the home environment. The Mother also explained that she had attended therapy sessions in the period from March to April 2026 for emotional support during what was, and remains an exceptionally difficult period in her life where she was separated from the Child, her access to him was significantly restricted and she was engaged in prolonged litigation and conflict. ⁸

40. I accept the Mother’s explanation. I would add that the Mother’s decision to seek professional support during periods of significant personal difficulty is, if anything, indicative of a degree of self-awareness and a willingness to manage her emotional state responsibly. It does not, in my view, point to an inability to parent safely. I would go further to say that a parent’s decision to seek mental health support, without more, ought not to be seized upon by the other parent as evidence that that the parent is unsafe to be around the Child. To treat the responsible act of seeking help as a basis for restricting a parent’s access would be to send entirely the wrong signal – it would discourage parents from seeking the support they need at precisely the moments when they need it most, for fear that doing so might be used against them in proceedings of this nature. The threshold for supervised access is not met merely because a parent has sought or is receiving mental health support, particularly where, as here, there is no evidence that the Mother's emotional state has manifested in conduct that is harmful to the Child.

41. Finally, in relation to the Father’s submission that the Mother poses a flight risk, I note that the 4 March Consent Order already restrains both parties from removing the Child out of Singapore without the written consent of the other party or further order of Court, and that the Child’s passport is presently held by the Father’s solicitors. Those safeguards substantially address the risk of unilateral removal and did not present a basis for insisting on supervised access after 4 March 2026.

42. Drawing the foregoing together, I am not satisfied that any of the grounds advanced by the Father — whether taken individually or cumulatively — establish a sufficient level of risk to the Child to justify the continuation of supervised access on an interim basis. The recordings do not show harmful conduct towards the Child; the incidents during access are at least partly attributable to the conditions under which access was being exercised; the Mother's engagement with mental health support does not establish a risk to the Child; and the flight risk concern is adequately addressed by existing safeguards.

43. As part of my orders made on 24 June 2026, I had also ordered that the Mother shall have overnight access with the Child to commence on a date after the next case conference. At the case conference on 7 July 2026, I had varied the initial parenting time orders to include one overnight per week. While the Father has taken the position that he was the principal parent involved in the nighttime routine, it does not appear to be his position that the Mother was completely uninvolved. I further note that the Mother had been breastfeeding and co-sleeping with the Child in his earlier years up until sometime in 2024, which the Father did not dispute ⁹ . At the same time, I am mindful that the Child has been subject to a supervised access arrangement for the better part of eight months and that a measured and gradual recalibration of the access arrangements is preferable to an abrupt change. One overnight per week as part of a structured weekend access period strikes the appropriate balance — it is sufficient to restore meaningful and regular contact between the Mother and the Child in an overnight setting, while allowing both the Child and the parties time to adjust to the new arrangements pending the Court's full decision.

44. I note with concern the Father’s practice of recording the Mother and the involvement of the paternal grandfather in monitoring and recording the Mother - such conduct unnecessarily raises the temperature between the parties and is also inconsistent with the Father’s professed support for the Child’s relationship with the Mother. I have addressed this in terms of the interim orders and I expect both parties to conduct themselves in a manner that prioritises the Child’s emotional comfort and wellbeing during parenting time and in a manner that promotes co-parenting.

45. It is evident to me based on the extensive evidence put forward that both parties have a deep love for the Child. As parties will have access to the contents of the private custody evaluation report, I encourage them to use it as an aid to resolve the matter expeditiously instead of spending their efforts and resources embroiled in litigation.