1 This decision addresses the appropriate access arrangements for a father seeking meaningful access with his young daughter, balancing the benefits of expanding access beyond present arrangements against the child’s need for stability and familiarity with those arrangements.

2 FC/OAG 114/2025 was filed by the Applicant Father (“Father”) on 25 July 2025, seeking access to the parties’ daughter (“Child”), who was slightly over 1 year old at the date of the hearing, on specified terms.

3 I heard the parties on 25 November 2025 and issued my orders on access with brief oral reasons. In summary, I ordered supervised visitation for the Father at FAM@FSC (now known as the Strengthening Families Programme, or “FAM”) (“SV”), with the access arrangements to be reviewed upon receipt of a report. Pending the conclusion of SV, I ordered the continuation of the existing access arrangements to preserve the status quo, albeit on slightly expanded terms.

4 The Father filed an appeal against my decision by way of HCF/DCA 153/2025. I now set out my full grounds of decision.

5 Parties registered their marriage in April 2023, and the Child was born in July 2024.

6 Following the parties’ marriage, they resided at their matrimonial home (“Matrimonial Home”), until the Respondent Mother (“Mother”) moved out with the Child in October 2024 after a heated quarrel between the parties (“October Incident”). ¹ Since then, the Mother and the Child have been residing at the Mother’s parents’ condominium (“Maternal Grandparents’ Residence”). It is undisputed that the Father has supervised access to the Child at the Maternal Grandparents’ Residence for one hour per week. Save for two occasions, ² the Father’s interactions with the Child have been largely confined to the living room of the Maternal Grandparents’ Residence, specifically the playpen area when the Child was younger.

7 In his application, the Father sought weekly unsupervised access, to be conducted at the Matrimonial Home or as otherwise agreed between the parties. He also sought unsupervised access during specific public holidays and special occasions on an alternating basis. In addition, the Father sought daily video call access with the Child via the Mother’s mobile number. While he initially sought only unsupervised daytime access, he subsequently expanded his position in his Written Submissions to include overnight access. ³

8 The Father contended that his access had been severely limited and unilaterally determined by the Mother and her parents. ⁴ He submitted that the one-hour access period was insufficient, and often ended abruptly without flexibility. For instance, his access was cancelled if the Child or the Mother were unwell. ⁵ The Father argued that these arrangements hindered his consistent and meaningful bonding with the Child. His interactions with the Child were also closely monitored by the Mother and/or her family members. ⁶

9 The Mother opposed the Father’s application. While she did not dispute that the Father ought to have more access with the Child, her main contention was that access should remain supervised and at the Maternal Grandparents’ Residence, rather than unsupervised at a neutral location. She further proposed that parties review the access timetable every two months, with a view to increasing the access duration and frequency.

10 The Mother cited the following reasons for her position:

(a) The Child is young and unfamiliar with the Father. ⁷

(b) The Father is unable to cope with the Child’s care, and is unfamiliar with her needs. ⁸

(c) The Matrimonial Home is an unfamiliar environment for the Child, and there is no evidence that it is suitable for the Child. ⁹

11 While the Mother proposed terms to allow her to take the Child overseas at her sole discretion, ¹⁰ she did not file a cross application on the issue of overseas travel. As neither party pursued this matter at the hearing, ¹¹ I did not make any orders on overseas travel or access.

12 The Father’s prayers and the parties’ respective positions on access are set out in Annex 1.

13 Having considered the evidence and parties’ submissions, I made the orders in Annex 2. My reasons, taking into account the Mother’s complaints about the Father’s conduct, and the Child’s familiarity with the Father, are as follows.

14 The Mother raised various complaints of the Father’s conduct, which she suggested were indicative of the Father’s inability to cope with the pressure of caring for the Child, and his unfamiliarity in caring for her needs:

(a) First, the Mother cited a main incident in September 2024 where she alleged that the Father had abandoned the Child, and subsequently chased her and the Mother out of the Matrimonial Home (“September Incident”).

(b) Second, the Mother also alleged that the Father was merely a passive participant in the Child’s care, and was unable to give the Child his full and undivided attention. She cited examples of the Father assisting with child-related chores only when instructed, and how he preferred to play video games instead.

15 I was unable to find that Mother’s complaints, taken on their own, necessitated the restrictive access arrangements sought by her, as I was satisfied that the Father had provided reasonable explanations for his conduct during the incidents raised by the Mother.

16 During the September Incident, I accepted the Father’s account that he had asked the Mother to leave the Matrimonial Home in a fit of anger, as he was upset over the Mother’s hurtful words to him. ¹² This was supported by the messaging records between parties, where the Father complained that the Mother had mentioned divorce and screamed in front of the Child. ¹³ There was no other evidence supporting the Mother’s claim that the Father had abandoned the Child out of frustration due to her crying. ¹⁴ I also noted that the Mother had eventually returned to the Matrimonial Home with the Child, and left again during the October Incident. The subsequent messaging records between parties in the aftermath of the October Incident referred mainly to disagreements over the Mother’s parents, and parties’ altercation over the Mother leaving the Matrimonial Home. They did not reveal any significant concerns about the Father’s general unsuitability to care for the Child, or safety issues. ¹⁵

17 As for the Mother’s allegations of the Father’s passive care of the Child, and his fixation on video games during childcare, I similarly did not find that the Father’s conduct was sufficient, in itself, to warrant the restrictions to his access as sought by the Mother.

18 In this regard, the Father provided messaging records for the relevant period demonstrating his care for the Child during the early stages, including performing chores associated with the care of the Child and night feeds. ¹⁶ Although there was no evidence of the Father’s continued bond with the Child subsequently, I was of the view that this could be attributable to the practical limitations of the family’s separate living arrangements, rather than the Father’s conduct.

19 I also found the Mother’s account of the Father’s occupation with video games to be overstated. There was no evidence that her complaints of the Father’s conduct of playing video games, or holding the Child while playing video games, even if made out, were to such extent as to put the Child in danger. ¹⁷

20 I was nevertheless mindful that the Father had not had extended periods of daytime or overnight access with the Child since October 2024, when she was only three months old. Even if the Father had been involved in the Child’s care when she was living with both parties (see [18] above), her needs and routines then as an infant would differ significantly from those of a toddler. It would also be unrealistic to suggest that the Child was familiar with the Matrimonial Home, having resided there only briefly when she was born. Instead, the Child would be accustomed to seeing the Father in the comfort of the Maternal Grandparents’ Residence, with her usual caregivers present. I therefore had concerns about the impact of any abrupt and drastic changes to this routine on the Child’s wellbeing.

21 The Father himself acknowledged that the Child would stay in the Mother’s parents’ bedroom for extended periods during his access visits. ¹⁸ This was consistent with the Mother’s evidence that the Child would often cry during the Father’s access. ¹⁹ The Father also recognised that he had not been a particularly present figure in the Child’s life, ²⁰ leaving aside the underlying reasons.

22 This was compounded by the lack of evidence regarding the Father’s experience in caring for the Child independently, or his understanding of the Child’s present needs. There were also no details of the Father’s plan for unsupervised access outside of the Maternal Grandparents’ Residence, or how his schedule could accommodate the Child’s routine. The Father also did not provide any evidence of the suitability of the Matrimonial Home or other proposed neutral locations for access, or to show how these venues were properly equipped for the Child. The Father’s Counsel was also unable to point me to any evidence of the Father’s envisaged arrangements for overnight access with the Child showing his readiness to provide appropriate care for the Child during such extended periods. ²¹ No explanation was provided as to why expanded access should be granted immediately, or on the factors that influenced the Father’s change in position.

23 Given my findings on the Mother’s complaints about the Father’s conduct, I was of the view that the Father’s unfamiliarity with the Child (and vice versa), may be attributable to the unsuitability of the existing access arrangements for meaningful bonding between the Father and the Child. The Father’s access was confined to the living room of the Maternal Grandparents’ Residence, with closed-circuit television cameras (“CCTV”) monitoring his access, ²² thereby limiting the activities and experiences he could share with the Child. His interactions were also subject to the scrutiny of the Mother and her parents, which was exacerbated by the Father’s strained relationship with the Mother’s parents, who had been critical of him. ²³

24 In the same vein, the existing arrangements provided the Child with little opportunity to develop familiarity with the Father. She had lived apart from the Father for more than a year, having been barely three months old when the Mother left the Matrimonial Home with her. She only had limited subsequent contact with the Father for one hour weekly at best, which was unilaterally determined by the Mother. ²⁴

25 I therefore agreed with the Father’s submission that he should have regular physical interaction with the Child. This was recognised by the Mother herself, although she disagreed as to how such access ought to be implemented. ²⁵ I was also of the view that access ought to be structured, rather than determined in a piecemeal manner at the Mother’s sole discretion.

26 However, I did not agree with the Father’s position that the access sought by him ought to be implemented immediately. Rather, I was of the view that the practical realities of this case, combined with the Child’s young age, necessitated an incremental approach to access. It would be in the Child’s best interests for her time with the Father to be gradually increased after their relationship and familiarity is re-established, and for the Father to be assisted during the period of transition by trained professionals. I therefore ordered weekly SV for the Father at FAM@FSC for eight sessions, to allow the Father to familiarise himself with the Child’s needs, bond with her, and learn how to care for her in a safe space without pressure or scrutiny from the Mother.

27 This incremental approach was similarly adopted in WQT v WQU [2023] SGFC 30. In that case, while the Court did not agree with the mother’s position that supervised access ought to be conducted at the matrimonial home with CCTV monitoring, it nevertheless ordered an initial period of supervised access at a Divorce Support Specialist Agency, as a transitory measure, to better equip the father to respond to the child’s needs. Such an approach was taken where the child had been having three hours of access in the matrimonial home to which the child was accustomed, compared to the more limited interactions between the Father and the Child in the present case. On appeal, the Court in WQT v WQU [2024] SGHCF 3 recognised that the District Judge was entitled to adopt a graduated approach starting with supervised access, given that the child was too young for unsupervised access. The Court also observed at [5] to [6] that supervised access may be necessary to help an estranged parent and child develop their relationship.

28 Similarly, in TQZ v TRA [2016] SGFC 99 at [9], the Court ordered SV to allow the father and child to be re-acquainted with one another in a controlled environment, and to prevent further allegations between the parties on access. The case involved a child who was almost two years old at the time of the orders, in circumstances where the Father had not had any access at all for eight months pending the court’s determination on the ancillary matters.

29 In this regard, I was of the view that the present case is distinguishable from WAG v WAH [2022] SGFC 17 (“WAG v WAH”), which the Father relied on to support his case for expanded access to be granted immediately on his terms. In that case, the Court found that the objective evidence demonstrated that the father had a close relationship with the child, being an intimate part of the child’s life since he was born. The Court also found that the child was familiar with the father, his paternal family, and the environment in question: see [122] of WAG v WAH. For reasons stated at [20] to [22] above, these factors were not established by the evidence in this case. It also bears noting that the Court in WAG v WAH had also adopted an incremental approach towards access.

30 In making my orders, I emphasised to parties that my decision should not be construed as a finding that the Father was an unsuitable caregiver for the Child. Rather, I was of the view that putting in place a structured transition period, with a view to establishing longer periods of unsupervised access after the conclusion of SV, would be in the Child’s best interests. The Court would then also have the benefit of a report, and the relationship between the Father and Child could be expected to have strengthened.

31 I nevertheless recognised that FAM@FSC SV could take some time, and may not be possible during special days and public holidays (periods for which the Mother was agreeable to access, albeit on reduced terms). I considered it beneficial to maintain the momentum of the present access arrangements while parties awaited the commencement of SV, and to preserve the Child’s regular contact with the Father in a consistent and familiar setting during the course of SV. Therefore, in tandem with SV, I ordered that the existing access arrangements were to continue both in terms of nature and venue, but extended from one to two hours, with additional time on the weekends. I also provided for special day and public holiday access, as well as makeup access, to ensure that the Father’s time with the Child was protected.

32 By maintaining the status quo with extended time purely to supplement and complement SV, this would ensure that practical limitations would not hamper the Father’s present contact with the Child. It would also provide familiarity and stability for the Child, while the Father received the necessary guidance and support from FAM@FSC.

33 I also deliberately structured the access orders pending the completion of SV to provide clear guidelines for parties, while keeping them sufficiently broad to allow parties to make adjustments based on the Child’s evolving needs and parties’ respective schedules. In particular, I was of the view that it would be in the Child’s best interests for access to be predictable and consistent, rather than based on the Father’s ad hoc requests, which could lead to scheduling conflicts and unnecessary allegations of “gatekeeping”. ²⁶

34 My orders were also designed to empower parties to communicate constructively, with a view to expanding existing access arrangements both in duration and scope. I encouraged parties to actively communicate with each other and be reasonable in the arrangements, using my orders as a framework. I explained that the Mother could, for instance, facilitate outings or activities between the Father and the Child outside on special occasions, or especially during her paternal grandparents’ birthdays.

35 Given my concerns about the Father’s limited familiarity with the Child, I also ordered that the Father was to be assisted by a third party during this initial access period. I found this to be a necessary arrangement to ease the Father into his role, given the Child’s young age, and the Father’s lack of caregiving experience. This should also address the Mother’s concerns about the Child’s needs being properly supported during this interim period. I left it to parties to agree on a suitable third party, and clarified at the hearing that the third party could be linked to either party. I also explained that access at the Child’s residence could extend beyond the house to include the vicinity of the residence.

36 I cautioned parties against unreasonable conduct, and urged counsel to impress upon their clients that any such conduct would be considered by the Court at the review hearing.

37 For completeness, the parties also sought other orders relating to access. The Father prayed for daily video call access. The Mother proposed that parties review the access timetable every two months, and also asked that the Court order that the Child not be exposed to the Father’s brother (“Brother”), whom she claimed was a violent drug abuser.

38 I declined to grant the Father’s prayer for daily video call access, as I was of the view that it would not be conducive for the Child given her young age. Based on the messaging records between parties exhibited in their respective affidavits, I concluded that such orders sought would not be feasible and would be counterproductive. Imposing additional communication requirements would likely aggravate existing tensions, rather than meaningfully benefit the relationship between the Father and the Child.

39 I also made no orders on the Mother’s proposal for scheduled mutual review of the access arrangements, and declined to prohibit any contact between the Child and specific third parties.

40 These orders were not sought by the Mother by way of application. In any event, I found that the evidence was insufficient for me to conclude that such prescriptive or prohibitive orders should be made.

41 For the proposed mutual review, whilst such review had been raised between parties previously, there was no evidence that parties had seriously or meaningfully pursued the same. ²⁷ In any event, in addition to the review to be conducted after the conclusion of SV, my orders on access were sufficiently broad to allow parties to undertake such mutual review, if necessary.

42 With regard to the Mother’s position that there should be a specific order prohibiting the Child’s contact with specific third parties, she cited messages between her and the Brother’s alleged ex-girlfriend stating that the Brother was a violent drug abuser. ²⁸ I found the Mother’s complaints about the Brother to be based on hearsay, with no details or any evidence of the extent of interactions between the Child and the Brother, or any resulting negative impact on the Child’s welfare should the restrictive orders sought by the Mother not be made.

43 Regardless, these were also matters that parties should take responsibility for as the Child’s parents, as they are expected to act reasonably in the best interests of the Child.

44 Following the making of my orders, the Father sought further arguments under Part 19 Rule 20 of the Family Justice (General) Rules 2024 on 2 December 2025. The request sought a revision of the access terms, after counsel disagreed on the exact terms of the order to be extracted, and following the Mother’s purported refusal to cooperate during the Father’s attempts to exercise his access on 26 November 2025 in accordance with my orders.

45 I declined to hear further arguments. Division 4 of Part 19, which concerns substantive final orders such as in the present case, does not provide for further arguments before a judge of the Family Court. Separately, the Father’s request also could not be considered as seeking permissible clarifications, as it sought substantive changes to my orders. It also sought to introduce new evidence by way of the request, rather than through an affidavit.

46 I highlighted to parties that the necessary arguments could be raised at the review session after a report is submitted by FAM@FSC to the Court. I also urged parties to agree on the wording of the draft order of Court for the purposes of extraction in accordance with the proper procedure.

47 To summarise, whilst I was of the view that Father should have more meaningful time with the Child, and there were no credible concerns mitigating against this, I found on the evidence that the practical realities of this case necessitated a graduated approach to the access arrangements. The father-child relationship after a substantial period of separation ought to be sensitively rebuilt rather than hastily imposed. SV, supported by carefully expanded access arrangements in the interim, would provide the necessary framework to assist both the Father and Child in this process of adjustment.

48 Parties sensibly submitted that there should be no order as to costs and I agreed, given that neither party could be said to be more successful than the other, and given the interim nature of the orders made.

1. The [Father] shall have weekly access to [the Child] as follows:

a. 2 weekday-access on Wednesday [and] Friday from 7pm to 8.30pm; and

b. 1 weekend-access (Saturday or Sunday) from 9.30am to 2pm.

2. a. Parties are to have on an alternate basis with the Child on these public holidays (except Chinese New Year and Christmas Day):

i. Odd Years starting 2025

I. Mother: New Year's Day, Good Friday, Vesak Day [and] National Day.

II. Father: Hari Raya Puasa; Labour Day, Hari Raya Haji [and] Deepavali.

ii. Even Years starting 2026

I. Father: New Year's Day, Good Friday, Vesak Day [and] National Day.

II. Mother: Hari Raya Puasa; Labour Day, Hari Raya Haji [and] Deepavali.

b. Public holidays (Chinese New Year and Christmas Day)

i. For Chinese New Year (“CNY”): For even years starting 2026, the [Father] shall have the eve of CNY from 9am to 9pm and day 1 of CNY from 9am to 9pm with the Child. The [Mother] shall have day 2 of CNY with the Child. For odd years starting 2027, the [Mother] shall have the eve of and day 1 of CNY with the Child, the [Father] shall have day 2 of CNY from 9am to 9pm with the Child.

ii. Parties to have Christmas Day with the Child for alternate years, commencing with the [Father] having the Child for Christmas Day from 9am to 9pm in 2025. On even years, the [Father] shall have the eve of Christmas Day with the Child from 9am to 9pm.

3. The [Father] shall have access to the Child on special occasions such as the Child's birthday, the [Father’s] birthday, Father's Day and paternal grandparents’ birthday from 10am to 6pm;

4. Such access pursuant to clauses 1 to 3 shall take place at the parties’ [Matrimonial Home] or otherwise as agreed by the parties;

5. Daily access via video call to the Child to be made to the [Mother’s] mobile number, at a time to be discussed and agreed by the parties;

6. Such further or other orders as this Honourable Court deems fit; and

7. That there be liberty to apply.

8. Costs in the cause.

1. The Father shall have weekly access to [the Child] as follows:

a. 2 weekdays access – unsupervised overnight access on Wednesday [and] Friday from 9am to 9am the following day; and

b. 1 weekend access – unsupervised overnight access from Saturday 9am to Sunday 9am.

2. Parties are to have on an alternate basis with the Child on these public holidays (except Chinese New Year and Christmas Day). The Father’s access shall be from 9am to 9am the following day.

a. Odd Years starting 2025

i. Mother: New Year’s Day, Good Friday, Vesak Day [and] National Day.

ii. Father: Hari Raya Puasa; Labour Day, Hari Raya Haji [and] Deepavali.

b. Even Years starting 2026

i. Father: New Year’s Day, Good Friday, Vesak Day [and] National Day.

ii. Mother: Hari Raya Puasa; Labour Day, Hari Raya Haji [and] Deepavali.

3. Public holidays (Chinese New Year and Christmas Day)

a. For Chinese New Year (“CNY”): For even years starting 2026, the Father shall have the eve of CNY and day 1 of CNY. Access shall be from 9am of the eve of CNY until 9am on day 2 of CNY. The Mother shall have day 2 of CNY with the Child. For odd years starting 2027, the Mother shall have the eve of and day 1 of CNY with the Child, the Father shall have day 2 of CNY from 9am to 9am the following day with the Child.

b. Parties to have Christmas Day with the Child for alternate years, commencing with the Applicant having the Child for Christmas Day from 9am to 9am the following day in 2025. On even years, the [Father] shall have the eve of Christmas Day with the Child from 9am to 9am the following day.

4. The Father shall have access to the Child on special occasions such as the Child’s birthday, the Father’s birthday, Father’s Day and paternal grandparents’ birthday from 9am to 9am the following day.

5. Such access above shall take place at a neutral location outside of the [Maternal Grandparents’ Residence] and free from CCTV surveillance and interference from the Mother’s parents as decided by the Father.

6. Daily access via video call to the Child to be made to the Mother’s mobile number.

1. All access shall be conducted at [the Maternal Grandparents’ Residence] and supervised by [the Mother] or a person of [the Mother’s] nomination.

2. The [Father] shall have access to the [Child] every Wednesday from 7:30PM to 8:30PM.

3. The [Father] shall also have supervised access from 7:30PM to 8:30PM on the following days:

a. The [Father’s] birthday;

b. Father’s day;

c. The day immediately after the [Child’s] birthday; and

d. The second day of Chinese New Year.

4. In the event that the days specified in (b) and (c) above overlap, there shall be no makeup or additional access.

5. [The Mother] shall be at liberty to take the [Child] overseas at [her] sole discretion. [She] will give the [Father] at least three weeks’ notice of any overseas trip. During said trips, the [Father] shall receive daily updates in the form of photographs or videos.

a. For the avoidance of doubt, the [Father] shall not be entitled to any makeup access or additional access in respect of access periods covered by the duration of the relevant overseas trip. Any and all such access periods are waived.

6. Parties shall review the access timetable every two months with a view towards increasing access duration and frequency. [The Mother] will not unreasonably decline to increase either duration or frequency. Parties shall also work towards granting the [Father] more/unsupervised access once the [Child] is of an appropriate age.

1. The Father shall have supervised visitation with the Child at FAM@FSC once a week for 8 sessions. Parties may be required to attend any other programme including counselling and/or assessment at the FAM@FSC, as determined by the FAM@FSC. A review is to be fixed by the Court after a report is submitted by the FAM@FSC to the Court.

2. Pending the conclusion of the supervised visitation and the Court’s review stated in [1]:

a. The Father shall continue to have weekly weekday access with the Child at her place of residence, save that the Father is to have access for 2 hours on a day/time to be mutually agreed between parties.

b. The Father shall additionally have weekly weekend access with the Child at her place of residence for 2 hours on a day/time to be mutually agreed between parties.

c. The Father shall additionally have access with the Child on special occasions such as the Child’s birthday, the Father’s birthday, Father’s Day, and the Child’s paternal grandparents’ birthday, as well as public holidays. Such special day and public holiday access is to be at the Child’s place of residence for 2 hours at a timing to be mutually agreed between parties.

3. To facilitate the Father’s access in [2]:

a. The Father is to be assisted during his access with the Child by a third party. Parties are to mutually agree on the suitable third party.

b. The Father shall be given make-up access should the Child be unable to attend an access session, on a date within 2 weeks of the missed access, to be mutually arranged between parties.

c. Parties are at liberty to agree on alternative venues and durations for the Father’s access with the Child.