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In the FAMILY JUSTICE Courts of the republic of singapore
[2026] SGFC 86
FC/D 5753/2023
FC/ECAO 13/2025
Between
YFC
Plaintiff
And
YFD
Defendant
Grounds of decision
[Family law] — [Ancillary powers of court] – [Division of matrimonial assets]
[Family law] — [Custody] – [Care and Control and Access to Children] – [Whether a switch of care arrangements is required]
[Family law] — [Custody] – [Enforcement of Child Access Orders]
[Family law] — [Child] – [Maintenance of Child]

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.
YFC
v
YFD
[2026] SGFC 86
Family Court — Divorce Suit No. 5753 of 2023 (Summons No. 1799 of 2025); Enforcement of Child Access Order No. 13 of 2025
District Judge Kevin Ho
26 September 2025, 17 October 2025, 13 November 2025, 6 January 2026, 27 February 2026; 17 June 2026.
29 June 2026
District Judge Kevin Ho
Introduction
1 These grounds of decision relate to the ancillary matters (“AM”) proceedings arising from the parties’ divorce in FC/D 5753/2023. In conjunction with the AM proceedings, the parties have (or had) several concurrent applications. These include:
(a) FC/ECAO 13/2025 (“ECAO 13”): An application for the Enforcement of Child Access Orders (“ECAO”) pursuant to inter alia s 126B of the Women’s Charter 1961 (2020 Rev. Ed.) (“WC”) filed by the Plaintiff-Wife (“Wife”) against the Defendant-Husband (“Husband”); and
(b) FC/SUM 1799/2025 (“SUM 1799”): The Wife’s application to vary the existing care and access order made on 28 April 2025 (“Interim Order”) in relation to the children of the marriage. The Wife, in essence, seeks a switch of the care and control of the children from the Husband to her.
(c) MSS 1195/2025 (“MSS 1195”): This was the Wife’s application to enforce the maintenance orders contained in the Interim Order, which the Husband had failed to comply with. MSS 1195/2025 was heard and finally determined on 17 October 2025 with the Court making the relevant enforcement order.
2 The above proceedings (and others which came before) provide a backdrop to the rather acrimonious proceedings (and relationship) between the parties arising from the Wife’s decision to end their approx. 9-year marriage. The parties married on 21 March 2015, and an Interim Judgment for Divorce (“IJ”) was granted on 17 July 2024.
3 The parties have 2 children of the marriage, [R] and [Z], who are 11 and 9 years old, respectively. I shall refer to them collectively as “the Children”. As part of the Therapeutic Justice Teams track (which this case was placed on), I had directed for the early preparation of a Custody Evaluation Report (“CER”) to assist the Court in understanding the family dynamics as well as the appropriate orders to be made for the Children.
4 As the docketed hearing judge, I presided over all the parties’ contested hearings (including the present AM proceedings, MSS 1195, ECAO 13 and SUM 1799). I also heard the Wife’s earlier application for interim care and access which led to the Interim Order being made on 28 April 2025. In making the Interim Order, I considered the contents of the CER and provided my reasons for the Interim Order in brief written grounds.
5 I had emphasised to the parties when I made the Interim Order that, by their nature, the orders contained therein were transitory and that the Court would be prepared to consider changes to the Interim Order at the final AM hearing. I also reminded both parties that their respective adherence to the terms of the Interim Order and overall conduct vis-à-vis the Children would be considered. Indeed, as it turned out, the Wife – through her filing of SUM 1799 and at the AM Hearing – sought further changes to the Interim Order.
6 During the AM hearing (which was heard together with ECAO 13 and SUM 1799), both the Wife’s counsel and the Husband (who was self-represented) confirmed that most of the AM issues were in dispute, save that the Wife was not seeking an order for maintenance for herself.
7 Coupled with the pending applications, the issues before the Court are thus as follows:
(a) in respect of the AM proceedings and SUM 1799:
(i) the appropriate custody, care and access orders which should be made in relation to the Children going forward;
(ii) the division of matrimonial assets pursuant to s 112(1) of the WC; and
(iii) the maintenance payable for the Children, post-divorce.
(b) in respect of ECAO 13:
(i) whether the Husband breached the Interim Order; and
(ii) if so, what orders should be made against him for these breaches.
Division of Matrimonial Assets
Pool of Matrimonial Assets
8 I start by dealing with the appropriate orders to be made for the division of parties’ pool of matrimonial assets (“Matrimonial Pool”).
9 In this regard, the Wife’s counsel helpfully summarised the contents of the parties’ Matrimonial Pool in her written submissions. The Husband, being self-represented, did not contest what has been summarised during his oral submissions at the AM hearing.
10 On the whole, I generally agree with the Wife’s summary which I found to have been based on the documents and evidence tendered in the AM proceedings. I will therefore adopt the said summary in these Grounds of Decision. That said, I note that the Wife has claimed that the Husband has been less than forthcoming in his assets disclosure in the AM proceedings.
11 In addressing and understanding the Wife’s claims, it is important to understand the relevance of the use of an operative date for determining what assets fall within the Matrimonial Pool, the date of valuation, and the role of adverse inferences in the context of the division of a divorcing couple’s matrimonial assets. These legal benchmarks and principles serve important roles when the Court assesses a divorcing couple’s assets.
12 The operative date is the date at which the Court will consider which assets falls within the Matrimonial Pool, and which do not. The Court of Appeal, in USB v USA [2020] 2 SLR 588 (“USB”), explained that “…[w]hen a marriage is dissolved, in general all the parties’ assets will be treated as matrimonial assets unless a party is able to prove that any particular asset was either not acquired during the marriage or was acquired through gift or inheritance and is therefore not a matrimonial asset…”: see USB at [31]. That is the starting point of the analyses.
13 The Appellate Division of the High Court (“ADHC”), citing long-standing case law from the Singapore courts, reiterated in WOS v WOT [2024] 1 SLR 437 (“WOS”) (at [25] of the judgment) that the default operative date is the date of Interim Judgment (or “IJ Date”) as that is the date which puts an end to the marriage. The Wife herself recognised this default position in her written submissions.
14 Neither the Wife nor the Husband has provided any reason for this Court to depart from the default rule of using the IJ Date. I will therefore use the IJ Date of 17 July 2024 as the operative date, in the present case.
15 Apart from the operative date, the Court is next concerned with the date of valuation of the matrimonial assets. The general (and thus default) rule is for the Matrimonial Pool to be valued at the date closest to the AM hearing date, except for the money held in bank and Central Provident Fund (“CPF”) accounts which would be valued as at the operative date (or close to it). In VTU v VTV [2022] SGHCF 23 (“VTU”), the General Division of the High Court (Family Division) (“HCFD”) explained the reason for this exception, ie, that the asset in question is the money in the accounts, and not the accounts themselves: see VTU at [2]; see also VIG v VIH [2021] 3 SLR 1145 at [12] and [13].
16 Once the above principles are recognised and applied, much of the Wife’s claims about non-disclosure of assets or inferences to be drawn falls away.
17 For example, the Wife points to the fact that the Husband withdrew a significant amount from his CPF Special Account on 2 April 2025 and that this constituted an improper dissipation of assets which should be “added-back” to the Matrimonial Pool. But there is, in fact, nothing to “add back” because the Court is concerned with what was in the Husband’s CPF accounts as at the operative date (ie, the IJ Date in July 2024) and not in April 2025, nor at the AM hearing date. It would therefore not matter if the Husband had withdrawn monies after the IJ Date since those monies would have been accounted for at the earlier date in July 2024.
18 Similarly, the Wife argued that the Husband’s “undisclosed rental income” from the parties’ matrimonial home should be accounted for. However, there is again no question of accounting for this “income”, or “adding-back” the same into the Matrimonial Pool. That is because what was present in the Husband’s bank accounts as at the IJ Date represents the assets liable for division. Regardless of whether the Husband had placed the rent collected in a joint account or sole named account, it would already be liable for division. However, what is divisible is what remains in the Husband’s bank account as at the IJ Date.
19 At this juncture, I wish to highlight that the Wife could have been clearer as to the exact nature of her arguments as regards the parties’ Matrimonial Pool. In my view, there are several possible distinct arguments which parties in a divorce can raise apropos the integrity and constituents of their Matrimonial Pool.
(a) First, an argument may be made that the other party (for eg., the Husband in the present case) had dissipated/transferred his/her money to someone else to hide the true extent of his/her personal wealth.
(b) Second, that the other party had improperly spent the money he/she had such that what should have been in his/her personal accounts was no longer there (at the IJ Date).
(c) Finally, one party may argue that the other has not complied with his/her disclosure obligations in the divorce proceedings in that the non-disclosing party has assets and monies which were not declared in his affidavits and that these are in fact matrimonial assets, then an adverse inference may to be drawn against the non-disclosing party.
All these are distinct arguments which attract different legal analyses.
20 For a party to succeed in argument (a) above, he/she must show proof that the other spouse had undertook an act of dissipation of assets. For argument (b), the asserting spouse must show that his/her situation within the legal principle known as the TNL Dicta.
21 In WOS (at [43]), the ADHC explained that the TNL Dicta legal principle recognises that “substantial sums expended during the period where divorce proceedings are imminent must be returned to the asset pool if the other spouse has at least a putative interest in it and has not consented, either expressly or impliedly, to the expenditure either before it was incurred or at any subsequent time”.
22 On the other hand, where the Court accepts that there has been material non-disclosure of assets in the course of the AM proceedings, it is open to the Court to draw an adverse inference against the non-disclosing party. The effect of a successful adverse inference argument may be that the Court quantifies (based on available evidence) how much the non-disclosing party had hidden away and add that amount back into the Matrimonial Pool (what is known as the “quantification approach”), or the Court may increase the overall percentage of the known assets awarded to the other spouse to account for the hidden assets (what is known as the “uplift approach”): see UZN v UZM [2021] 1 SLR 426 at [28].
23 In the present case, if the Wife claims that the Husband has hidden streams of income which he had not disclosed, the question is whether this alleged income were placed in some hidden account which should have been divided as matrimonial assets. If so, the above analysis should be undertaken.
24 However, if the Wife’s claim is merely that the Husband is earning more than he claims, then that is not an argument relating to the division of matrimonial assets, but of his earning/income earning abilities or capacity. Such arguments may be relevant to the issue of maintenance, but it is not a reason to increase the amount the Wife should get in the division of assets, or the increase the Matrimonial Pool.
25 Unfortunately, the challenge before the Court in the present case is that the Wife’s submissions did not draw the above distinctions clearly, choosing instead to include all her concerns with the Husband’s conduct as generic arguments for adverse inferences to be drawn in respect of the Matrimonial Pool.
26 Be that as it may, the above discussion provides a useful framework to explain the Court’s analytical approach towards the issues relating to the Matrimonial Pool, and to provide context to my decision not to “add-back” additional assets into the Matrimonial Pool. To reiterate, I find what has been disclosed by the parties in their respective affidavits (and which was summarised by the Wife’s counsel in her written submissions) to be an accurate reflection of the Matrimonial Pool and no further adjustments or changes are necessary in the present case.
27 Accordingly, the parties’ Matrimonial Pool is as follows:
Table 1 – Matrimonial Pool
S/No.
Asset
Husband
Wife
Remarks
1
Matrimonial Flat
$835,868.22
See [29] below
2
CPF Accounts
$167,510.15
$224,086.68
PA1 at p. 145;
DA1 at p. 110
3
Bank Accounts
(excluding CDA accounts)
$996.52
$8,220.38
PS at [123];
DA1 at [22]
4
Insurance Policies / Investments
$89,050.00
$16,325.35
PS at [123];
See [36] below
5
Shares in [DCPE] Pte Ltd
$100,000
0
See [41] below.
Sub-Total
(Excluding Matrimonial Flat)
$357,556.67
$248,632.41
Total: $606,189.08
Total Matrimonial Pool Value
$1,442,057.30
With Matrimonial Flat
28 In assessing the net value of the Matrimonial Pool, I have taken into account various assertions raised by the Wife, including the values to be ascribed to the parties’ matrimonial property and the Husband’s personal assets, as well as a plethora of allegations made by the Wife in regards the Husband’s conduct in the course of the divorce proceedings. I will address these in the following paragraphs.
Matrimonial Property
29 For the parties’ Housing and Development Board (“HDB”) flat located at southern part of Singapore (“Matrimonial Flat”), I have used the $1,050,000 as the property’s estimated current market value.
30 This value is based on the Wife’s solicitor’s correspondence to the Court on 4 May 2026 setting out the relevant HDB resale information of recent transaction prices for properties similar to the Matrimonial Flat, and on a similarly high floor. I had also considered the Husband’s letter to the Court dated 11 May 2026 setting out his views on the value of the Matrimonial Flat.
31 The Wife – through her counsel’s letter – acknowledges that the price range for similar units is between $1,028,000 and $1,070,888 but asserts that the property should be valued at only approx. $900,000 (a marked decrease from her initial valuation of $1,010,000 in her earlier submission). In this regard, the Wife attempts to reduce the valuation figure by referring to the poor condition the property is in.
32 Respectfully, I do not accept the Wife’s assertions as – unlike the transaction prices which are publicly available information – she has not proved the poor state of the Matrimonial Flat nor has she shown that those other units sold in excess of $1 million were of a better or worse state as compared to the Matrimonial Flat. Her claims are far too speculative to be accepted.
33 Moreover, the Husband disputes the Wife’s claims. He asserts that the Matrimonial Flat is kept clean and in good condition. Overall, he submits that the value should be in the region of $1,000,000.
34 Having considered the matter, I find the figure of $1,050,000 to be appropriate and reasonable. This figure is the approximate median value in the range of values provided by the Wife. In fact, from the documents tendered by the parties, similar units have been sold in excess of $1.1 million in 2025. The $1,050,000 is this consistent with recent transaction prices.
35 Finally, I accept the Wife’s figure of $214,131.78 as representing the outstanding loan on the Matrimonial Flat. This means that the net value of the Matrimonial Flat would be $835,868.22.
Insurance Policies
36 As regards the Husband’s insurance policies, much ink was spilled on whether the Husband owned undisclosed insurance policies with HSBC Bank. I make two broad observations with the respect to the Wife’s allegations:
(a) Undisclosed Policies. Insofar as the Wife alleges that there are “undisclosed” policies, I am not persuaded that these were valuable policies which had been hidden from her and the Court. While the Husband did fail to disclose 2 policies, I accept that the Husband did allow the Wife access to his bankers at HSBC Bank to conduct the relevant inquiries.
(b) The two policies referred to by the Wife (ie, polices ending with -3977 and -3993) were disclosed in HSBC bank’s email dated 14 August 2025 addressed to the Wife, and copied to her solicitors.
(c) I am not persuaded that the Wife has proven that these assets were in existence prior to the operative date (ie, the IJ Date). Even if they were, these policies – by their description as “HSBC Life Shield – Plan A” – appear to be healthcare policies and are not “assets” per se. In fact, the nature of HSBC policies bearing the name “HSBC Life Shield – Plan A” as being integrated shield plans based on Singapore Medi-shield / Medisave related insurance schemes were discussed by the parties extensively in December 2025.
(d) It was open to the Wife to pursue the relevant discovery application (including third-party discovery applications) if she truly believed that these were valuable assets, but she did not do so. As the High Court had noted in WLL v WLM [2023] SGCHF 19 (at [9]), “[a]n adverse inference cannot be used as a remedy to a lapse by the party in the interlocutory process.” I am thus not prepared to draw any inference or ascribe a value to these policies.
(e) Withdrawals from HSBC Policy ending -9274. The Wife argues that she has uncovered 2 unexplained withdrawals against the surrender value of the policy amounting to $15,013.28 which she wants to “claw-back”. Again, I am not persuaded that there is a basis to do so.
(f) The Wife was informed of these withdrawals by an email from HSBC bank dated 18 August 2025. There were 2 withdrawals – one in November 2023 and one on 4 April 2025.
(g) The challenge I have is that the Wife fails to appreciate that the value of the policy – which she had used in her written submissions – was already the value as at November 2024. That being the case, there is no need to account for the $12,034.15 withdrawal in April 2025 because the value used was that which was before this withdrawal.
(h) As regards the $2,979.13 withdrawal on 8 November 2023, the Wife made no specific submission as to why this amount ought to be added back, save for a general assertion regarding the withdrawal of policy monies. I note that this withdrawal was carried out even before divorce proceedings had been commenced, and many months before the IJ Date.
(i) While this withdrawal could potentially come under the TNL Dicta principle, no such arguments were advanced by the Wife in her written submissions.
(j) In any case, the value I have used for this policy (ie, $28,293) is already at the higher end of the range suggested by the Husband. As such, I find that this value would sufficiently account for any difference in value as a result of the 8 November 2023 withdrawal.
Other Assets
37 With respect to the Wife’s claim that the Husband had: (i) claimed tax relief improperly; (ii) misused financial aid and assistance given to the family; (iii) misused the Children’s Child Development Accounts; (iv) not disclosed the Children’s medical insurance details, I am of the view that these are not matters which relate to the Matrimonial Pool nor are they reasons to enlarge or reduce its size (whether by reason of an adverse inferences to be drawn against the Husband or otherwise).
38 As such, I will not adjust the Matrimonial Pool any further because of these assertions. If the Wife believes that something illegal or improper had taken place, she is free to take legal advice on her rights or make the necessary reports to the relevant authorities. But these are not matters relevant to the division of the parties’ matrimonial assets.
39 In respect of the Husband’s shareholding in [DCPE] Pte Ltd (“Company”), the Wife alleged, in her submissions, that an adverse inference ought to be drawn against him and that the Court should “consider whether an uplift” in the Wife’s share of the assets is “warranted”. However, she did not explain how this uplift ought to be given, and to what extent.
40 Granting an uplift in the percentage awarded to the Wife from the known assets is an inherently imprecise and speculative method. While it may be resorted when there is no better option, care must be taken when deciding to do so, including the availability of other methods.
41 In the present case, there is another proxy which can be used – ie, the Company’s paid-up capital. While this value is not necessarily the same as its current market value, it is the best available information to the Court to assess the value of the Company. The use of such a proxy is neither new nor novel – a similar approach was used by the HCFD in WZF v WZG [2025] 3 SLR 1219, where Mohamed Faizal JC (as he then was) aptly noted as follows (at [66]):
66 […] While I agree with the Husband’s reasoning, the paid up capital of the company serves as a useful (and the only) starting point for assessing its value in the absence of any detailed financial information. After all, the paid up capital represents the nominal value of the shares issued by the company and reflects the value of the initial equity investment. While this is admittedly not always or even commonly co-related with the shares’ actual present value (which incorporates a multitude of other factors), it represents a sensible base line and, is, in any event, the only available relevant proxy for the value of the Husband’s shares in the company. Of course, it may very well be, as the Husband asserts, that it is no longer a fair reflection of the current market value, or that he bought the shares at a different price. However, in the present circumstances, given that the Husband is intentionally not furnishing any data point to the court for its consideration, the Wife’s representation of the value of the paid-up capital owned by the Husband represents the only meaningful proxy available.
[Emphasis added in Bold]
42 As the HCFD had observed, the paid-up capital of a company may be used as a proxy for its value in the absence of any other information, particularly in cases where the actual owner of the Company (ie, the Husband in the present case) has refused to provide the relevant documents to prove its true value.
43 Here, I recognise that the Wife had indeed requested – through the discovery process –all the relevant financial statements, audited/unaudited accounts of the Company. The Husband, however, refused to provide the same. He did not even disclose the existence of the Company (and his directorship and shareholding in the Company) in his initial affidavits until this was uncovered by the Wife later on.
44 Moreover, although he had tried to prove the Company’s dormancy by reference to payments made to one [TMC] Pte Ltd for corporate management services, the documents themselves suggest that filing fees were incurred by these consultants to file the Company’s annual returns and annual general meeting documents. In other words, the Company had financial documents but these were not provided by the Husband.
45 As the Husband owns 100,000 of the Company’s 200,000 shares, and the paid-up capital of the Company is $200,000, I will include a sum of $100,000 as the notional value of the Company back into the Matrimonial Pool.
Ratio of Division
46 Having addressed the value of the Matrimonial Pool, I now move on to determine the appropriate ratio of division.
47 I start with a brief discussion on the approach which I will adopt in dividing the parties’ matrimonial assets. In general, where the marriage involved dual incomes (ie, both spouses were working and had accumulated assets because of such income) the structured approach recognised in ANJ v ANK [2015] 4 SLR 1043 (“ANJ”) would be used. That is the approach advocated by the Wife’s counsel in her submissions.
48 In my view, the ANJ approach is the correct approach and should be used in the present case given the dual-income nature of the marriage. The alternate trends-based approach (per TNL v TNK [2017] 1 SLR 609) would not be appropriate as it is only used in single-income marriages and represents an exception to the general rule that the ANJ approach should be used in most cases: see XKU v XKT [2026] SGHC(A) 7 at [41] and [46].
49 Accordingly, the Court will apply the ANJ approach, which can be summarised as comprising the following steps:
(a) First, the court should ascribe a ratio that represents each party’s direct contributions having regard to the amount of financial contribution each party has made towards the acquisition or improvement of the matrimonial assets;
(b) Second, the court should ascribe a second ratio to represent each party’s indirect contribution to the well-being of the family relative to that of the other;
(c) Third, using each party’s respective direct and indirect percentage contributions, the court derives each party’s average percentage contribution to the family that would form the basis to divide the matrimonial assets; and
(d) Further adjustments may need to be made to the parties’ average percentage contributions to take into account, among other things, the other facts enumerated in s 112(2) of the WC.
(See WQP v WQQ [2024] 2 SLR 557 at [49])
50 For completeness, I will use the “global assessment” methodology (as noted by the Court of Appeal in NK v NL [2007] 3 SLR(R) 743 at [31] and [35]) in dividing the Matrimonial Pool. This means I will use a single division ratio applies to all of the parties’ matrimonial assets globally. Neither party addressed this issue in their written or oral submissions, but I am of the view that this represents the appropriate approach since there are no reasons given to use different ratios for different classes of assets.
ANJ Approach: Direct Financial Contributions (“DFC”)
51 In the present case, the parties’ respective DFC may be determined relatively straightforward as the only significant joint asset is the Matrimonial Flat.
52 As regards the parties’ sole-named assets, their current value would be used as a proxy for their respective DFC to the marriage. Such an approach is consistent with the prevailing legal principle on such matters: see UTJ v UTK [2019] SGHCF at [56]; see also WTL v WTM [2024] SGHCF 40 at [34] and [35]; WFE v WFF [2023] 1 SLR 1524 at [37]. Thus, when assessing the appropriate DFC ratio, the Court takes into account both the joint asset’s apportionment, and their respective sole-named assets.
53 I note that the Wife’s submissions provided alternative approaches – one where all of the parties’ assets are included, and another where “only the Matrimonial [Flat] is to be included”. It is not clear to me why there ought to be two different approaches nor was there any good reason provided for the Court to include only the Matrimonial Flat into the Pool. Thus, I will follow the usual approach and include all of the parties’ assets.
54 Returning to the parties’ Matrimonial Flat, there is no disagreement on their contributions made through payments from the parties’ CPF accounts. The only disagreement is with the Wife’s claim that she had made cash contributions of $10,000 towards the purchase of the Matrimonial Flat, which the Husband disagreed with during the AM Hearing.
55 In my view, the Wife has not adequately proved her assertion. This $10,000 cash payment was not raised in her first AM affidavit, and there are no clear supporting documents substantiating this claim. I am therefore not persuaded that this amount should be allowed as representing her additional contribution towards the Matrimonial Flat.
56 Using only the parties’ CPF-based payments, a total of $374,432.95 had been paid towards the Matrimonial Flat. This is based on the information provided in the parties’ earliest AM affidavits given the Court’s focus on their contributions closer to the IJ Date. This total amount comprises $212,913.45 (paid by the Wife) and $161,519.50 (paid by the Husband).
57 Accordingly, the current net value of the Matrimonial Flat should be apportioned in the ratio of 57 (Wife) : 43 (Husband), based on the amount they had paid to purchase the said Flat.
58 The parties’ respective DFC should therefore be:
Table 2 – DFC Ratio
S/No.
Asset
Husband
Wife
Remarks
1
Matrimonial Flat
$359,423.33
$476,444.89
$835,868.22,
apportioned
57(W):43(H)
2
CPF Accounts
$167,510.15
$224,086.68
3
Bank Accounts
(excluding CDA accounts)
$996.52
$8,220.38
4
Insurance Policies / Investments
$89,050.00
$16,325.35
5
Shares in [DCPE] Pte Ltd
$100,000
0
Total:
$716,980.00
$725,077.30
Total:
$1,442,057.30
DFC Ratio
49.7%
50.3%
ANJ Approach: Indirect Contributions (“IDC”)
59 I now address the appropriate IDC ratio to be ascribed to the parties’ indirect financial and non-financial contributions. In this regard, the ADHC recently reiterated the well-established approach which the Court should undertake when evaluating the divorcing parties’ IDC in XHG v XHH [2025] 2 SLR 501. The ADHC held as follows (at [87] and [90] of the judgment):
87 […] We begin with the guidance provided by the Court of Appeal in USB v USA and another appeal [2020] 2 SLR 588 (“USB v USA”) at [43] (which this court recently reaffirmed in WXW v WXX [2025] SGHC(A) 2 at [17]):
… the broad-brush approach should be applied with particular vigour in assessing the parties’ indirect contributions. This would serve the purpose of discouraging needless acrimony during the ancillary proceedings. Practically, this means that, in ascertaining the ratio of indirect contributions, the court should not focus unduly on the minutiae of family life. Instead, the court should direct its attention to broad factual indicators when determining the ratio of parties’ indirect contributions. These would include factors such as the length of the marriage, the number of children, and which party was the children’s primary caregiver.
[…]
90 The broad factual indicators point to a marriage where the Husband made greater indirect financial contributions to the well-being of the family, while the Wife made greater indirect non-financial contributions. This is not to say that the Husband did not make substantial indirect non-financial contributions or that the Wife did not make substantial indirect financial contributions at all. Indeed, the Judge found that the Husband had been an active father who also made substantial contributions in the Children’s lives (Judgment at [36]). The task of the court is to weigh the substantial contributions from both the Husband and the Wife in this case in the twin spheres of their indirect financial and non-financial contributions.
[Emphasis added in bold]
60 I thus focus on the broad indicators – this was a marriage of about 9 years, with 2 children born to this marriage. The Wife, herself, has a child from a previous marriage.
61 In respect of the Wife’s non-financial contributions, I accept her submission that she was the Children’s primary caregiver in the Children’s initial years before her departure from the Matrimonial Flat in 2023. She also made contributions in the area of home-making and the management of familial affairs. The Wife detailed much of her efforts and contributions in her Affidavit of Assets and Means and these were not contested and/or substantively rebutted by the Husband in the various affidavits he has filed in the AM proceedings. In fact, the Husband acknowledged that the Wife had been the person managing the family’s financial matters in the initial years.
62 I also find, even after 2023, that the Wife had contributed to the care of the Children, including on the education-related matters. These contributions are important and relevant to the Court’s consideration.
63 For indirect financial contributions, I find the Wife to have contributed substantially including during the period where the Husband could not do so (eg., from November 2018 to May 2019). To be clear, my findings vis-à-vis the Wife’s contributions is not a dismissal of the Husband’s efforts. I accept that he too contributed financially to the family, including towards the renovation of the Matrimonial Flat and household expenses. He also supported the Children financially as they are living with him.
64 But, as emphasised by the ADHC, the task of the Court is to weigh both parties’ contribution. In my view, the Wife’s overall contributions were greater in this weighing exercise.
65 Accordingly, I find that a reasonable IDC ratio to be 60:40, in favour of the Wife. This ratio is broadly in line with cases involving similar length and number of children (see for eg., BNS v BNT [2017] 4 SLR 213; VBR v VBS [2019] SGFC 123; TPY v TPZ [2017] SGHCF 2). I have also taken into account the nature of each party’s contributions in the present case.
ANJ Approach: Final Ratio
66 Based on the matters set out above, the final ratio of division would be:
Table 3 – Final Ratio
Husband
Wife
Remarks
DFC Ratio
49.7
50.3
Equal Weightage
IDC Ratio
40
60
Final Ratio
45
55
Rounded to nearest whole number
67 In reaching the final ratio, I have applied equal weightage to both the DFC and IDC ratios, as neither party argued for a different approach. The Wife’s counsel’s submissions also placed equal weightage on the 2 ratios.
68 As to whether any adjustments should be made to the final ratio, the Wife’s submissions alluded to her claim that an adverse inference ought to the drawn against the Husband, and that an “uplift” ought to be given to the Wife. As I have already addressed the adverse inference arguments above and have accounted for assets held on by the Husband (see [26] above), I see no reason to provide for any additional uplift to the final ratio.
Implementation
69 Finally, I address how the aforesaid division ought to be implemented.
70 The proportions which each party is entitled to as part of the division of assets should be as follows:
Table 4 – Apportionment of Assets
Husband
Wife
Remarks
Final Ratio (ANJ)
45%
55%
Party’s share/apportionment of the Matrimonial Pool
$648,925.79
$793,131.51
Total asset pool:
$1,442,057.30
Less
Assets in parties’ sole name
($357,556.67)
($248,632.41)
Amount due to Party from the Sale of the Matrimonial Flat
$291,369.12
$544,499.10
Ratio of Sale Proceeds
(if sold)
35%
65%
71 Based on the Table above, the Wife should receive $544,499.10 from the sale of the Matrimonial Flat, and the Husband is to receive $291,369.12. The Wife, in her Ancillary Matters Fact and Position Sheet, had asked that the Matrimonial Flat be transferred to her. However, she did not explain how this is to be effected, or how the Husband’s share is to be accounted for.
72 Be that as it may, I will allow the Wife to keep the Matrimonial Flat provided the Husband’s share of the same is paid to him. In the event that the transfer cannot be carried out, there would be a sale of the Matrimonial Flat in the open market. I have set out at [131] below the specific orders I will be making.
73 Save as set out above, I will order that each party will keep his or her own sole-named assets.
Children’s Issues
74 I now move on to the next (and possibly the most serious) area of contention between the parties, ie. the appropriate care and/or access orders which should be made in relation to the Children.
75 The question of whether the Children should reside with the Husband or the Wife post-divorce is also deeply intertwined with the substantive orders sought in SUM 1799 and the appropriate orders to be made for ECAO 13.
76 It goes without saying that the law places the Children’s welfare and best interest at the centre of any dispute over their upbringing and well-being. That is (and remains) the key legal imperative in s 125 of the WC. The Court of Appeal in WKM v WKN [2024] 1 SLR 158 at [1] (“WKM”) reiterated the importance of the welfare principle, and its role as the “golden thread” which runs through all proceedings affecting the interests of children.
77 Various cases from the HCFD, the ADHC, and the Court of Appeal have explained that the concept of the Children’s “welfare” must be understood in the widest sense. This requires the Court to adopt a multi-factorial approach and consider a variety of matters including inter alia the need for stability, the continuity of living arrangements, as well as the desirability of keeping siblings together: see ABW v ABV [2014] 2 SLR 769 (at [20] – [23]). The Children’s developmental needs and the need for them to form (and develop) good relationships with both parents are also important considerations.
Custody
78 I start with the issue of the custody orders for the Children.
79 When I made the Interim Order, it was generally agreed by the parties that there should be an order for joint custody. However, bearing in mind the disagreements between the parties, I provided specific exceptions to the joint custody to provide for situations where there may be disagreements to the Children’s education-related matters. Such orders may be granted when there may be an impasse between the two parents in decision-making for major issues involving the Children: see CXR v CXQ [2026] SGHCF 12 (“CXR”) at [26]. I found it necessary, on the facts of the present case, to put in place such impasse provisions.
80 That said, I note that the Wife has asked for an order of sole custody in her AM Fact and Position Sheet. Like the HCFD in CXR, I am not persuaded that she has shown sufficient basis for such a draconian order. The Court of Appeal’s reminder in CX v CY [2005] 3 SLR(R) 690 (at [38]) remains relevant today – an order for sole custody is an exceptional order for exceptional circumstances. While the relationship between the parents in the present case is undoubtedly acrimonious, there is no evidence to show that the Husband has abused the Children, or that co-parenting is impossible.
81 In my view, the orders made in the Interim Order should generally continue as I see no good reason to vary the same. I will, however, make minor linguistic adjustments to better reflect the Children’s present situation (which would have superseded the situation envisaged in the Interim Order) and the orders which I will be making herein.
Care and control, Access to the Children
82 I move on to the issue of the care and control order for the Children. This is the issue which both the Husband and the Wife’s counsel spent the most time on during the hearing, and in their respective submissions.
83 For context, I had – through the Interim Order – granted interim care and control to the Husband. I had explained, when I made the said order on 21 April 2025, that this temporary care arrangement was meant to preserve the status quo at that time (while the divorce proceedings were underway) and should not be taken as the Court having found any one parent as the “better” parent or that the other was not capable of caring for the Children. I emphasised that I expected the Husband to follow the spirit and intent of the Interim Order, and that compliance with the relevant care and access orders therein was an important consideration in whether those arrangements can continue.
84 It is at this juncture where the matters raised in ECAO 13 become relevant. To recapitulate, in ECAO 13, the Wife claims that the Husband had breached the Interim Order on no less than 46 occasions, including 10 breaches which had occurred while the ECAO proceedings themselves were underway.
85 It is important to understand that at paragraph 1(i) of the Interim Order, I had made clear the following positive obligation impressed on the Husband:
(i) The [Husband] shall take all necessary steps to facilitate the aforesaid access arrangements with the [Wife]. The [Husband] is not entitled to cancel, change or reschedule the above access arrangements without the [Wife]’s consent, and shall not arrange or schedule any activities or overseas trips during the [Wife]’s access period without her consent.
[Emphasis added in bold]
Put simply, the terms of Interim Order do not allow the Husband to unilaterally change any terms of the Wife’s access to the Children. It expressly does not allow him to withhold access for any reason. No exceptions to this had been granted by the Court.
86 In other words, the Husband is not allowed to cancel or reschedule access simply because he believes the Children are unwell, or that he has made plans for the Children, or even if the Children does not feel well or does not feel like going to the Wife’s residence. None of those are acceptable reasons to change (much less deny) access.
87 This is a critical point, the context of which is important. Paragraph 1(i) of the Interim Order was included precisely to address the concern that the Husband (being the care parent) may make ad hoc or unilateral changes to the Children’s access time on the pretext of other commitments or schedules. I had alluded to this very concern when making the Interim Order.
88 In making the Interim Order, I did not find the Wife to be a danger to the Children or that she had no care-giving capacity. To the contrary, I had – in other parts of the Interim Order – vested primary decision-making authority with her for the Children’s educational matters as I found her to be better placed to make such decisions. The Wife would therefore be in a position to address any medical, emotional or safety concern which may arise during (or prior to) access such that she (as the Children’s mother) would be capable of handling and resolving the situation. I should point out that, in the course of the trial of ECAO 13, the Husband accepted and acknowledged that the Wife was not a danger to the Children and that she can provide a safe environment for the Children.
89 I emphasise that the terms of the Interim Order are clear and unambiguous, and was made as such to avoid unnecessary arguments and/or disagreements. The Husband was also represented by his previous solicitors when the Interim Order was made. Despite this, the Husband sought to put his own “interpretation” to the Interim Order and sought to be excused for having “misunderstood” the same. I do not accept the Husband’s explanations as there was nothing in the Interim Order which could have caused the Husband to misunderstand its scope.
90 In my view, the Husband was clearly aware of the obligations imposed under the Interim Order but had chosen to act in a manner which does not comply with it. Where he was required to facilitate access to the Children under the Interim Order, there were occasions where he failed to do so.
91 As such, I find that the evidence – both adduced by the Wife through the affidavits filed for the ECAO 13 and through the Husband’s own oral testimony at trial – supports a finding that the Husband had breached the Interim Order. I find that the Wife has proved this beyond reasonable doubt.
92 For completeness, in the following paragraphs, I set out various observations and views in relation to ECAO 13 given the Wife’s written submissions had raised these matters for the Court’s consideration, and in light of the fact that the ECAO regime itself is relatively new.
93 First, the Wife’s counsel submitted that the ECAO regime is of a quasi-criminal nature with the possibility of penal sanctions and orders. As such, the Wife submits that the appropriate standard of proof should be akin to the standard used in criminal proceedings, ie, proof beyond reasonable doubt.
94 The Wife – in her written submissions – also cited and referred to various legal principles applicable to committal proceedings (as applied in civil or family cases) which she submitted as also being applicable to cases filed under the ECAO regime. The Husband, being self-represented, did not address the Court on these legal issues.
95 I agree broadly with the Wife’s counsel that principles similar to those applied in committal proceedings ought to be applicable for the purpose of ECAO proceedings. These legal and procedural requirements are necessary to provide sufficient safeguards in committal proceedings given the serious consequences entailed (eg., the possible imprisonment of the contemnor). The higher intensity orders under the ECAO regime also involve similar serious consequences (including the imprisonment of the parent in breach), and supports the need for adopting similar procedural safeguards.
96 Moreover, there is nothing in the relevant Parliamentary debates in the passing of the Women’s Charter (Amendment) Bill 2022, creating the ECAO regime, which suggests that Parliament had intended for a different (or lower) legal standard to be applied in ECAO cases: see Singapore Parliamentary Debates, Official Report (10 January 2022) Vol. 95, Sitting No. 44 (Sun Xueling, Minister of State for Social and Family Development), Second Reading of the Women’s Charter (Amendment) Bill.
97 I also agree with the Wife that insofar as the mental element (or mens rea) to support a charge for the breach of a Court Order is concerned, the motive or reasons for disobedience of the party in breach are not relevant to the question of liability: see Mok Kah Hong v Zheng Zhuan Yao [2016] 2 SLR 1 (“Mok Kah Hong”) at [86]. This is the same approach taken in committal proceedings for breaches of court orders.
98 Second, following from the points discussed above, I have thus confined my findings on the breach of the Interim Order (for the purpose of the ECAO proceedings) only to those which have arisen prior to the filing of ECAO 13 on 25 July 2025, ie, the 14 incidents referred to in the Wife’s affidavit filed for ECAO 13. This is in keeping with the approach taken in committal proceedings where the supporting affidavit (or the “Statement” under the older Family Justice Rules 2014 (“FJR 2014”)) generally delineates the boundaries of the applying party’s case: see Mok Kah Hong at [61].
99 I recognise that in the context of civil and family committal proceedings, the Court has the discretion to allow the applicant to go beyond what has been stated in Statement filed under the old Rules of Court or FJR 2014 (see Aero-Gate Pte Ltd v Engen Marine Engineering Pte Ltd [2018] SGHC 267 (at [58] – [60]); see also r 762 of the FJR 2014). While that may potentially be applicable in ECAO proceedings as well, I would keep to what has been alleged in the Wife’s ECAO affidavit, in the present case, since neither party addressed this specific issue in their closing submissions.
100 That said, had it been necessary for me to do so, I would have found that the Husband would not have been prejudiced (or taken by surprise) by the time of the trial of ECAO 13 in October 2025 that the Wife intended to rely on further incidents of breach which occurred between July 2025 and September 2025. Indeed, these incidents were expressly raised in the Wife’s affidavits filed SUM 1799 and the AM hearing, many of which were filed prior to the trial of ECAO 13.
101 To recapitulate, I find that the Husband had breached the Interim Order on the 14 dates identified by the Wife for the purpose of finding liability in respect of ECAO 13. I will address the appropriate remedy for these breaches later on.
102 To avoid doubt, the remaining incidents of breaches – while not considered in the context of the ECAO proceedings – have not been entirely disregarded by the Court. In my view, these incidents (many of which were substantiated by video evidence provided by the Wife) support the Wife’s case that the Husband had been clearly obstructive to her access to the Children. His actions – which he believes to be what is good for the Children – have, on occasion, the effect of influencing the Children to take an antagonistic view of access time with the Mother.
103 The Husband thus did not facilitate access in a manner which would encourage the Children to spend time with the Wife (despite whatever personal misgivings he may have). In fact, the evidence presented at the hearing of ECAO 13 and the AM hearing was clear – the Husband’s behaviour served to distance the Children from the Wife. Video recordings were presented to the Court where the Husband had sought to exert pressure or influence over the Children. On one occasion in June 2025, the Police had to be called in when [R] wanted to spend time with the Wife when he was ill. The Husband could be seen in the video repeatedly asking [R] whether he really wanted to stay with the Wife and/or that he could change his mind since the police were around. This led to [R], a young child, being interviewed by the Police as to what his preferences were that day. No child should be made to go through such emotional turmoil. A disagreement over child access matters is not a criminal offence, nor is the [R] a victim or a perpetrator.
104 On another occasion in October 2025 (while the proceedings were ongoing), the Wife had visited the Matrimonial Flat to pass the Children some sweet treats to consume for Children’s Day but this was met with aggression by the Husband, who took the cakes purchased by the Wife, exited the Matrimonial Flat, followed the Wife to lift landing, and threw the food at the Wife. Once again, this interaction was captured in a video recording tendered to the Court.
105 Unfortunately, when viewed holistically, the events of the past year have rendered the arrangements in the Interim Order to be no longer suitable for the Children or in their welfare or best interests. That is regrettable as I had – through the Interim Order – hoped to set a pathway for the parties to share care and control but the Husband’s behaviour (including his failure to comply even with the maintenance aspect of the Interim Order which necessitated a maintenance enforcement order in MSS 1195) thus far has not been conducive to the co-parenting efforts.
106 Accordingly, I am of the view that the Wife (and not the Husband) should have sole care and control of the Children going forward.
107 I understand that the Husband may well be disappointed by the decision, as he firmly believes that he is the better caregiver for the Children. However, I am concerned that keeping the Children under his care would affect their bond with the Wife.
108 In VLA v VLB [2020] SGFC 73 (at [22]), the Family Court aptly noted that “it is the right of the child to be afforded the opportunity to establish a continuing relationship with both parents and it is not for either parent to decide to exclude the other from the child’s life”.
109 It is not for one parent (even if there may exists unhappiness or acrimony with the other parent) to decide or dictate how the other parent should interact with the children. Certainly, he cannot set up unreasonable or unnecessary boundaries to “curate” how the other parent should be interacting with their children.
110 The HCFD in VPG v VPF [2021] SGHCF 18 discussed the concept of a “strong parent” as one who supports the child in having a close relationship with the other parent. I made a similar point to the parties when I made the Interim Order, reminding them to be bigger, wiser and kinder, and that should not involve the children in their personal conflict. These reminders, however, clearly did not resonate with the Husband who, despite being the care parent in the past year pursuant the Interim Order, made the mother-children interaction fraught with difficulty and contestations.
111 Indeed, these incidents were amply covered during the trial of ECAO 13, and the incidents covered under the ambit of SUM 1799. The evidence showed the Children (especially [Z]) being drawn into the conflict and triangulated between the two parents. On several occasions, [Z] had been required to convey the Children’s alleged “wish” to change access plans (in breach of the express requirement of the Interim Order) and, in doing so, she referenced concepts such as the order for care and control, access. There is no reason why an 8-year-old should be doing so if she had been properly insulated from the parents’ ongoing dispute.
112 Overall, I am satisfied that the Children should be in the Wife’s care going forward. To be clear, I remain of the view (as I did in making the Interim Order) that the Children would benefit with the involvement of both parents and a shared care order may be possible in the future. For now, however, the Children’s interest would be best served if they were to be in the Wife’s care.
113 As for the appropriate orders, I summarise them briefly as follows:
(a) The Wife shall have care and control of the Children with effect from 17June 2026, with the Children residing with her.
(b) After the change in care and control, the Husband will have access to the Children for weekly overnight access on weekends, and a fortnightly weekday dinner access. The Husband’s access arrangements will commence in mid-July 2026.
(c) All other terms (set out in the Interim Order) relating to the care and access arrangements for the Children during school holidays, public holidays and other special occasions will broadly continue to apply save that I have made adjustments to take into account the change in the Children’s care arrangements to the Wife.
114 In making the above orders, I have provided for the switch of the Children’s care to the Wife to take place in June 2026 when the Wife would have school holiday access to the Children. This would be less disruptive to the Children. Following the switch, the Children will remain in the Wife’s care (and in her residence) for an uninterrupted period of 3 weeks up until the second week of July 2026 (“Transition Period”).
115 During this Period, the Husband is entitled to video/telephone call access to the Children twice a week. This provides him with an opportunity to check-in on the Children’s wellbeing, but he should not be using these calls to pressure or unduly influence the Children, or to persuade the Children to disregard the Court’s orders.
116 The aforesaid transition period would provide the time and space required for the Children to get accustomed with the Wife’s residence. I need to emphasise that the Wife was the Children’s caregiver in the past and there is no real need for acclimatisation to the Wife. Rather, this period is for the establishment of routine and other day-to-day arrangements. This Transition Period also recognises the Wife’s entitlement to make-up access for the multiple breaches of the Interim Order (for which ECAO 13 had been brought).
117 The Husband’s access to the Children (which would be consist of weekly overnight access on the weekends and a fortnightly dinner access) would commence after the 2-week period. Although this might appear to be a reduction in the Husband’s access time with the Children, I find it necessary to ensure that the Children would gain a measure of stability after the change in the care and control order and to address any triangulation which they may have been exposed to during the past year. The Husband would still have substantial access time during the school holiday period for him to maintain his bonds with the Children.
118 I hope that, in time, the Children and the parties would reach a position where the Husband’s access to the Children during the school term can increased gradually. I have provided for the parties to vary the access orders by written consent if they wish to. When necessary, the appropriate application can be filed to adjust the Husband’s access time in the future.
119 In the interest of clarity, I will make these orders as part of the Court’s AM orders so that are relevant orders are contained in one single order (as opposed to orders made under 3 separate applications). Consequently, I make no orders for ECAO 13 and SUM 1799.
120 Further, I would remind both parents that:
(a) They should continue to work with the professional counsellors which have been appointed pursuant to my earlier order for counselling (through the Strengthening Families Programme (FAM) by the Ministry of Social and Family Development, and the Family Service Centre).
(b) This is especially important during and after the Transition Period. The professionals will work closely with the family, and both parents should respect the views and opinions provided. Recommendations should also be followed.
(c) Time is needed to provide a stable and safe environment for the Children. Both parties should thus refrain from taking unnecessary or provocative steps which may cause distress to the Children – including unnecessarily seeking the intervention from external agencies (including law enforcement agencies) – when there are no real safety concerns. The evidence presented at the ECAO hearing clearly showed that the use of the police to intervene in handover or custody disagreements had placed undue stress and fear to the Children, such as the example with [R] I had alluded to above.
121 My detailed orders are set out at [131] below.
Maintenance for the Children
122 As I have granted the Wife sole care and control of the Children, I find that the Husband should contribute to the Children’s maintenance by making maintenance payments to the Wife (as the Children’s caregiver moving ahead).
123 In her written submissions, the Wife set out an aggregate claim of $3,460 as maintenance for both Children. I set out my assessment of these claims in the Table below.
Table 5A – [R]’s Expenses
S/no.
Expense Item
Wife’s Claim ($)
Court’s Assessment ($)
1
Housing, Utilities, Internet
220
50
2
Grocery, School Meals
250
200
3
Fees, Uniform, Transport
60
50
4
Medical, Insurance
150
0
5
Toiletries, Haircut,
Clothing
50
30
6
Tuition: Math/Science/MTL
800
780
7
Entertainment, Sport, Travel
250
50
Total
1,780
1,210
Table 5B – [Z]’s Expenses
S/no.
Expense Item
Wife’s Claim ($)
Court’s Assessment ($)
1
Housing, Utilities, Internet
250
50
2
Grocery, School Meals
150
150
3
Fees, Uniform, Transport (School Bus)
250
250
4
Medical, Insurance
150
0
5
Toiletries, Haircut,
Clothing
50
30
6
Tuition: Math/MTL
800
450
7
Entertainment, Sport, Travel
250
15
Total
1,900*
1,402
* stated as “$1,680” in the Wife’s written submissions.
124 Having scaled down the Wife’s claim for what are reasonable expenses, I conclude that the Children’s total reasonable monthly expenses amount to approx. $2,600. This amount includes the costs of the Children’s tuition and enrichment classes. I need to reiterate that in the Interim Order, I had expressly allowed the Wife to determine the Children’s educational needs and requirements. This would encompass the relevant tuition and/or enrichment classes.
125 In the Wife’s latest AM affidavit, she has explained that the costs of tuition are estimated to be $260 per month per subject (for a Primary 5 child, ie, [R]) and $220 per month per subject (for a Primary 2 child, ie. [Z]). I adopt those figures to three subjects (math, science and mother tongue) for [R] and two subjects (math, mother tongue) for [Z]. These are based on the subjects which the Children are taking currently. There is no basis for the Court to speculate what they may or may not need in the future. The appropriate recourse would be via an application to vary maintenance should there be a material change in circumstances.
126 Next, although the law does allow for the provision of reasonable accommodation expenses for the Children (see WBU v WBT [2023] SGHCF 3 at [29] – [30]), I have not provided for the full amount claimed by the Wife (ie, $250 per child) which appears to cover “Housing, Utilities, Internet”. The present case is unique in that it is the Wife who had sought a switch of care and control, and thus I find it reasonable that she would have had to provide for a suitable place of residence for the Children. The Wife herself has explained that she had secured accommodation for herself, her elder child and her mother. In other words, she already has suitable accommodations. There is no need to provide for an additional accommodation expense (which, in any event, had not been adequately proven).
127 Apart from the above, I have scaled down the various categories of expenses to what I find to be reasonable amounts, having regard to the Children’s lifestyle and/or needs. In so doing, I am mindful that an order for Children’s maintenance should not cover items of luxury: see WOS v WOT [2023] SGHCF 36 at [50].
128 Overall, I will order the Husband to pay to the Wife a monthly sum of $1,600 for both Children (being $740 per month for [R], and $860 per month for [Z]). This amount represents approx. 62% of the Children’s monthly expenses. The ratio of 62 (Husband) : 38 (Wife) broadly reflects the parties’ monthly net salaries. I have not included bonuses and overtime pay given their discretionary nature.
129 Finally, the Wife had indicated in an earlier affidavit that she sought an order for lump sum maintenance for the Children’s maintenance, although this was no longer actively pursued at the AM Hearing. To be clear, I decline to make any order for lump sum maintenance given that the Children’s needs may vary over the years and it would be too speculative to fix a definite amount now, when they are still in Primary school. For the same reason, I also do not accept the Wife’s submission that there should be a built-in adjustment mechanism of 2% per annum to account for rising living costs given the inherent speculative nature of such mechanisms.
130 To ensure a clean slate, I will allow the parties to deduct from any amounts payable by the Wife to the Husband in my orders herein, any maintenance arrears due from the Husband to her pursuant to, save that the Wife must account for any part-payments towards any maintenance arrears (or outstanding payments under ORC 1389) which the Husband has made since the time MSS 1195 had been disposed-of. To avoid doubt, this would include any additional arrears which accrued for the Children’s education expenses on or after March 2026 for which the Husband has already made part-payment of.
Conclusion
131 In the premises, I made the final AM orders as set out in the Annex hereto, incorporating the clarifications to the orders I had made subsequently.
132 After I delivered my decision to the parties on 17 June 2026, I directed both parties to tender their written submissions on the issue of costs by 22 June 2026. After considering these submissions, I ordered that the Husband pay to the Wife costs fixed at $5,000 (all-in) on account of the outcome in ECAO 13, SUM 1799 and the AM hearing.
Kevin Ho
District Judge
Ms Dharmambal Shanti Jayaram
(Dharma Law LLC) for the Plaintiff;
Defendant-in-person.
ANNEX
Custody, Care and Control, and Access of the Children
1 The parties shall have joint custody of the children of marriage, [R] (Birth Certificate No. T15XXXXXX) and [Z] (Birth Certificate No. T17XXXXXX) (collectively, the "Children"), save that:
(a) The Plaintiff shall be at liberty to solely determine the ​Children's educational-related matters.
(b) The Plaintiff shall give reasonable notice to, and obtain the views of, the Defendant before making any such decision in respect of the Children's educational-related matters.
2 With effect from 17 June 2026, the Plaintiff shall have care and control of the Children. To avoid doubt, the Children are to reside with the Plaintiff, and the Defendant is to facilitate the aforesaid change of care to the Plaintiff. Upon the change of care and control to the Plaintiff:
(a) There shall be no physical access to the Children for the period between 17 June 2026 and 10 July 2026 (“Transition Period”).
(b) The Defendant’s access to the Children shall only commence from 11 July 2026, after the Transition Period. To avoid doubt, this period includes the make-up access to be granted to the Plaintiff arising from the Defendant’s breach of the access orders made in FC/ORC 1389/2026.
(c) During the Transition Period, the Defendant shall be entitled to have telephone/video call access to the Children twice a week on Wednesdays and Sundays at 6.30pm, for a period of up to 15 minutes. The Plaintiff is entitled to be present during these telephone/video calls.
3 School Term Access. Subject to (4) below, the Defendant shall have access to the Children during their school term as follows:
(a) from 10am on Saturday to 10am on Sunday; and
(b) one weekday dinner from 5pm to 8pm every fortnight, on such time as the parties may mutually agree.
4 School Holidays. The Defendant’s access to the Children during school holidays is as follows:
(a) For the Children's school holiday period in March and September, the Defendant shall have access as follows:
(i) from 10:00 am on the Saturday immediately after the last Friday of the previous school term to Tuesday, 6:00 pm; and
(ii) the Defendant’s usual school terms access (as stated at (c) above) shall start on the school week after the end of the March and September school holidays.
(b) For the Children's school holiday period in June and December, the Defendant shall have access as follows:
(i) to both Children for the second half of school holidays on odd numbered years (e.g. 2025, 2027, 2029) and the first half of the school holidays on even numbered years (e.g. 2026, 2028 etc); and
(ii) the school holiday access commences on the first day of the relevant school holiday period as determined by the Ministry of Education,
(c) The abovesaid school holiday access shall take precedence over the regular school term access as set out at paragraph (3) above.
5 Public Holidays and Special Occasions.  The following access arrangements take precedence over the access arrangements as set out at paragraph (d) above.
(a) in relation to Good Friday weekend, the Plaintiff shall have parenting time for the entire weekend, and the Defendant’s access to the Children on the following school term weekend shall be extended from Saturday 10am to Sunday 8pm.
(b) on years where the Plaintiff's school holiday parenting time do not cover the Christmas period, the Plaintiff shall have additional overnight parenting time from 12 noon on Christmas Eve through to 9:00 pm on 26 December. 
(c) In relation to Hari Raya Haji, the Defendant shall have access to the Children from 9:00 am to 9:00 pm if this holiday falls within the Plaintiff's parenting time.
(d) In relation to Hari Raya Puasa, the Defendant shall have overnight access with the Children from 12 noon Hari Raya Puasa Eve to 9:00 pm on the day of the celebrations.
(e) For Chinese New Year ("CNY"):  On even numbered years (2026, 2028, 2030), the Plaintiff shall have overnight parenting time from 9:00 am on CNY Day 1 to 9:00 pm on CNY Day 2.  On odd numbered years (2027, 2029, 2031), the Defendant shall have overnight access from 9:00 am on CNY Day 1 to 9:00 pm on CNY Day 2.
(f) Other Public Holidays (as gazetted):  Each party shall have parenting time/access from 9:00 am to 9:00 pm on alternate public holidays.
6 Parents'/Children's Birthdays:  Where the child's or parent's birthday does not fall within that parent's parenting time/access, the other parent shall be entitled to 4 hours of parenting time/access on the relevant day from 5:00 pm ​to 9:00 pm.
7 Overseas Travel. The parties shall be entitled to take the Children overseas subject to the following:
(a) For all overseas travel (of more than 1 day) during a parent's parenting time or access period (as the case may be), the travelling party shall provide to the other parent, 2 weeks before the intended travel, the relevant travel details including travel dates, itinerary, flight and accommodation details and emergency contact information. 
(b) For all overseas day trips, the travelling parent shall give 5 days' notice of such travel to the other parent and shall provide the relevant travel/accommodation details and emergency contact information
(c) The Plaintiff is to provide the Defendant with the Children's passports to facilitate the overseas travel, and the Defendant shall return the same to the Plaintiff at the end of any such trip. Save as is required for overseas travel, the Plaintiff shall retain the Children’s passport for safekeeping and the Defendant shall deliver-up the same to her.
(d) Neither party shall be allowed to impose additional conditions and/or restrictions on the other to travel overseas with the Children.
8 The Defendant shall pick up the Children from the Plaintiff’s place of residence (or a mutually agreed location) and shall return them home after access.
9 To avoid doubt:
(a) The Defendant must return the Children to the Plaintiff after each access period and shall not be permitted to retain the Children in his care for any reason (including but not limited to the Children falling ill, or the Children’s preference, etc.) without the Plaintiff’s consent.
(b) The Plaintiff is to take the necessary steps to facilitate the Defendant’s access, including ensuring that all the Children are available during the access time, and that no other activities shall be planned during such time.
10 Neither party is to disparage or make negative comments of the other parent, his/her religion, and/or his/her family members, in front of the Children, or to share information regarding court proceedings with them without the other parent’s consent.
11 The parties are at liberty to mutually agree to vary the above access arrangements, with such agreement to be recorded in writing.
12 The parties and the Children are to continue to attend counselling at FAM@FSC. The parties are to respect the views, opinions, and recommendations provided by the professional counsellors.
Division of Matrimonial Assets
Option A: Transfer of Defendant’s Share
13 The Plaintiff is at liberty to elect to acquire the Defendant’s share of the parties’ matrimonial property at [XXX] (“Matrimonial Flat”) as follows:
(a) the Plaintiff is to give written notice to the Defendant within 2 months from the date of this Order that she intends to take over the Defendant’s share in the Matrimonial Flat;
(b) the Defendant shall be entitled to receive an amount equivalent to $291,369.12 (“Defendant’s Entitlement”);
(c) within 3 months after notice (as set out above) has been provided, the Plaintiff shall :
(i) make all necessary refunds to the Defendant Central Provident Fund (“CPF”) account of the amount used by him in the acquisition of the Matrimonial Flat together with the accrued interest as required by the applicable CPF laws, rules and/or regulations (“CPF Refund Amount”); and
(ii) the Plaintiff shall pay to the Defendant, in cash, the difference between the Defendant’s Entitlement and the CPF Refund Amount;
(d) the Defendant shall transfer (other than by way of sale) his rights, title and/or interests in the Matrimonial Flat to the Plaintiff upon receiving the amounts stated in paragraphs (ii) above; and
(e) the Plaintiff shall be solely responsible for the costs and expenses of the transfer (if any). To avoid doubt, the Plaintiff shall be responsible for securing all necessary refinancing and/or mortgage for the Matrimonial Flat such that she alone would be responsible for any mortgage and/or loan in relation to the Matrimonial Flat after the aforesaid transfer.
Option B: Sale of Matrimonial Flat
14 In the event that the Plaintiff elects not to take over the Defendant’s share of the Matrimonial Flat (as set out above), the said property shall be sold in the open market within 6 months from the date of this Order. The parties shall have joint conduct of the sale.
15 The Matrimonial Flat shall be sold at or above the sale price of $1,050,000 (or such other amount as the parties may agree in writing).
16 The proceeds of sale of the Matrimonial Flat should then be applied as follows:
(a) to discharge the outstanding mortgage and/or housing loan in respect of the property;
(b) to pay the costs and expenses of the sale (including agent’s fees); and
(c) the remainder proceeds of sale of the Matrimonial Flat shall be divided in the proportion of 65 (Plaintiff) : 35 (Defendant).
17 Each party shall be responsible for making the required CPF refunds to their respective CPF accounts from their share of the sale proceeds.
18 The parties may, by agreement in writing, extend the deadline for the sale or transfer of the Matrimonial Flat, as the case may be, set out above.
Other Matrimonial Assets
19 Save as set out above, each party shall retain all other assets in their name (whether owned solely, or jointly with third parties).
20 The Registrar and/or Assistant Registrar of the Family Justice Courts under Section 31 of the Family Justice Act 2014 is empowered to execute, sign or indorse all necessary documents relating to the matters contained in this Order on behalf of either party should either party fail to do so within seven (7) days of written request being made to the party.
Maintenance for the Plaintiff
21 There shall be no maintenance for the Plaintiff.
Maintenance for the Children
22 With effect from 1 July 2026, the Defendant shall pay to the Plaintiff the sum of $1,600 per month as maintenance for the Children. The amount should be deposited into the Plaintiff'​s POSB Savings Account No. [XXX-XXXXX-X] on the 1st day of each calendar month.
23 To avoid doubt, the Defendant is to continue to ensure that the Children are to be appropriately covered by the necessary medical and/or hospitalisation insurance. Where the Children’s medical expenses are not covered by insurance, the parties shall bear the said expenses in the proportion of 60 (Defendant) : 40 (Plaintiff).
24 To avoid doubt, the parties may deduct from any amounts payable by the Plaintiff or due to, the Defendant, under this order any amount arrears in maintenance arising from FC/ORC 1389/2026 on or after 17 October 2025 (which do not already form part of EMO XXXX/2025), save that the Plaintiff must take into account any part-payments made by the Defendant towards such maintenance arrears.
25 Liberty to apply.
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Version No 3: 30 Jun 2026 (12:38 hrs)