[2026] SGFC 88

In the FAMILY JUSTICE Courts of the republic of singapore

[2026] SGFC 88

SSP 698 of 2025

SSP 699 of 2025

Between

XPR

… Applicant

And

XPQ

… Respondent

grounds of decision

[Family Law — Family Violence — Orders for Protection]

[Family Law — Family Violence — Application to Revoke Personal Protection Order]

[Family Law — Family Procedure — Use of Generative Artificial Intelligence in drafting Witness Statements/Affidavits]

[Family Law — Family Procedure — Costs]

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.

XPR
v
XPQ

[2026] SGFC 88

Family Court — SS 698 and 699 of 2025
Magistrate Soh Kian Peng
10, 11, 18, 22 July, 3 September 2025

30 June 2026

Magistrate Soh Kian Peng:

1 There were two applications before me. Both were filed by the Husband. The Wife was the Respondent to both applications. These were the orders which the Husband had sought:

(a) SSP 698 was the Husband’s application for a Personal Protection Order (“PPO”), Domestic Exclusion Order (“DEO”), Counselling Order (“CGO”) and Mandatory Treatment Order (“MTO”) for the Wife.

(b) SSP 699 was the Husband’s application to revoke a PPO that the Wife had obtained against him more than a decade ago.

2 I heard the trial of the matter over several days. Judgment was reserved. Parties were directed to file written submissions. Judgment was handed down on the 3rd of September 2025. These are the reasons for my decision.

The Use of Generative Artificial Intelligence in Preparing Written Statements or Affidavits

3 As a preliminary point, I first deal with the issue of the Husband having used generative Artificial Intelligence (“AI”) in the preparation of the written statements which he had submitted to court for the trial of both SSP 698 and 699.

4 This issue had come up at the close of trial. The Husband had, in attempting to argue that the Wife’s counselling reports also be disclosed to him, cited me a case which, upon conducting a LawNet search, did not exist.

5 Curious as to how the Husband had managed to cite me a fictitious case, I queried him on the source of his information. It came to light that he had obtained that information from generative AI.

6 I then asked the Husband if he had used generative AI in the preparation of the documents which he had submitted to court. It subsequently transpired that he had indeed used generative AI to prepare the two written statements which he had submitted to court, and relied upon at the hearing before me.

7 The first statement, “H1” was 109 pages in length (this contained some 93 pages of exhibits which included photographs of documents as well as written statements that the Husband had filed in the concurrent divorce proceedings). The second statement “H2” was 255 pages in length. It contained no exhibits.

8 Given this, I directed the Husband to file an affidavit stating, amongst other things, whether he had used generative AI to prepare documents which he had submitted for SSP 698 and 699, and if so, he was to give details of which generative AI tools he had used, and how he had used them.

9 The Husband filed his affidavit in compliance with my directions. In that affidavit, he stated that he had only used text-based versions of generative AI tools, and that he did not use generative AI to “create, alter or fabricate” any evidence. He also stated that he used generative AI to create first drafts of legal documents such as requesting “empty standard templates for affidavits with placeholder fields for litigant names”, and that he would carefully review and revise these templates. Finally, the Husband stated that he did not use generative AI for “creating any personal factual content, evidence, or statements of personal knowledge related to” his case. The Husband then goes on to set out, in detail, how he had prepared his documents. The gist of it was that, according to him, he had “exclusively authored and prepared” all documents relating to this case without help from any other person.

10 I had every reason to doubt the Husband’s declaration that generative AI had not been used to produce any “personal factual content, evidence, or statements of personal knowledge related to” his case.

11 For one, during the course of his testimony earlier in the trial, I had asked the Husband whether he had prepared both H1 and H2 by himself. He confirmed that he had done so.

12 I then further queried the Husband on how he had prepared both documents. He told me that he had prepared his written statements though a combination of typing and relying on the speech to text function. Given his subsequent declaration affirming his use of generative AI in the preparation of these statements, it was clear that what he had said in this part of his testimony was not entirely true.

13 Aside from this, there was also the speed at which these written statements had been prepared. In particular, the procedural history showed that H2 had been prepared in the span of two weeks.

14 I had first seen parties at a mentions on 2 June 2025. At that mentions, counsel for the Wife, Mr Jagjit Singh Gill (“Mr Gill”), confirmed that his client had filed her Affidavit of Evidence in Chief (“AEIC”).

15 At the next mentions on 23 June 2025, Mr Gill informed the court that he had, on the 17th of June 2025, received H2 (which was essentially the Husband’s reply to the Wife’s AEIC which had been filed earlier).

16 It must be noted that during the course of these two weeks, there were ongoing divorce proceedings between the Husband and the Wife. In fact, the Husband had also put before me the decision of my brother judge (dated the 5th of June 2025) in respect of the Wife’s application to strike out the Husband’s Defence and Counterclaim in the divorce.

17 That the Husband had managed to peruse the entirety of the Wife’s AEIC (which comprised 126 paragraphs across 63 pages together with 164 pages of exhibits) and compose a lengthy response in H2 within the span of two weeks, whilst managing the divorce process all on his own, without the benefit of any legal training, was, in my view, telling as to the manner in which he had prepared his written statement in H2.

18 Finally, there was also the structure and syntax of his written statements which, when considered together with the other facts I have set out above, strengthened the inference that the Husband had possibly used generative AI to produce the factual contents of those statements.

19 I had, upon perusing the Husband’s written statements prior to the start of trial, noticed, as I have mentioned, that its structure and syntax were somewhat peculiar. This led me to query the Husband on whether he had prepared his statements by himself, and how he had done so (see above at [11] – [12]). For instance, I found it curious that he would refer to himself, sometimes in the first person, and sometimes in the third person:

We specifically request a court order to declare [the Wife] an unreliable witness and a fabricator, and to strike out her pervasive lies from the record. This entire serial number is a collection of baseless accusations, rhetorical distortions, and transparent attempts to shift blame, all serving as irrefutable evidence of her unreasonable behavior and her role as the true vexatious litigant. We vehemently apply to strike out this serial number as scandalous, frivolous, and demonstrably false.

…

The fact that I need food bank assistance, and cannot even afford MRT fare to pursue my cases without MSF financial aid, further demonstrates her systemic deprivation and my genuine destitution.

20 There was also how, for example, H2 was structured. The Husband’s response would begin with either a complete reproduction of a paragraph of what the Wife had stated in her affidavit, or an extract of a paragraph from the Wife’s affidavit. What followed was a summary of the Wife’s claim in that paragraph. This was then followed by the Husband’s response. For example:

18. The incidents of family violence leading to the PPO application include [details of alleged family violence].

• Her Claim: She would likely detail specific incidents of alleged family violence from my part that she claims led to her PPO application.

• Our Refutation and Application to Strike Out: Any specific incidents she may cite as justification for her 2010 PPO are, as repeatedly asserted in my affidavit… without substantial verifiable evidence and are largely stale, irrelevant allegations. For over a decade since the PPO was granted, she consistently stopped reporting any incidents of family violence from my end, an improbable claim for a genuinely threatened party. This glaring absence of subsequent reports, coupled with the fact that I am now the one seeking protection orders against her for her ongoing unreasonable behavior, critically undermines the credibility of her historical claims. Her decision to cease reporting incidents, ostensibly to "protect our son," is a self-serving and improbable claim, as a truly concerned parent would prioritize genuine safety over maintaining a false narrative. The Registrar's decision to uphold 100% of my claims of her unreasonable behavior directly contradicts any assertion that I was the sole perpetrator of family violence then or now. Her re-hashing of these old, unverified, and questionable allegations is a vexatious attempt to defame me and distract the Court from her current pattern of abuse. We apply to strike out these alleged incidents as irrelevant and unsubstantiated.

…

21. Sometime in January 2012 the Applicant applied for a PPO for himself and also a De-Exclusion Order. Copies of the Applicant's applications are exhibited at pages 142 - 150.

• Her Claim:

She acknowledges that I applied for a PPO for myself and a De-Exclusion Order sometime in January 2012.

• Our Refutation and Application to Strike Out:

This acknowledgment, while factually correct that I filed these applications, is significantly decontextualized and aims to obscure the critical reasons behind my urgent need for protection. My application for a PPO for myself was a direct response to her ongoing, escalating unreasonable behavior and violence, which continued even after her fraudulently obtained PPO against me in 2011. The very act of me seeking protection for myself, and a De-Exclusion Order, directly contradicts her fabricated narrative of me being the aggressor and her being the sole victim. This application was a desperate attempt to address the severe physical, psychological, and financial abuse I was enduring. We emphasize that this claim, while true, is presented in a decontextualized manner to diminish its significance.

21 Given the doubt I had as to whether the Husband had used generative AI to produce the factual components of the written statements, and in that vein, whether he had actually taken the effort to verify the accuracy of these written statements which he relied on at trial, I decided that I would place no reliance on the written statements which the Husband had filed in H1 and H2.

22 It must be remembered that an affidavit, or an unsworn statement, is a document of much significance. That is because these documents are the primary mode in which a witness’s evidence-in-chief is given at a trial. That much is clear from the Family Justice (General) Rules 2024 (“FJ(G)R”) which provide that the evidence in chief of a party, or a witness, is to be given by affidavit of evidence in chief: P 15, r 16(1) of the FJ(G)R. In special cases, the court may allow the party or the witness to give evidence orally, or by an unsworn statement: P 15, r 16(2) of the FJ(G)R. Further, as was noted by the High Court in United Overseas Bank Ltd v Lippo Marina Collection Pte Ltd and others [2018] 4 SLR 391 at [63]:

63 Even if Cadbury Schweppes cannot be distinguished, I would respectfully not follow it. In respect of the holding that a finalised witness proof intended to be given to an adversary is not protected by litigation privilege, the primary justification in Cadbury Schweppes appears to be that such a proof would have been created “for the purpose of serving them on the [adversary]” (at [37]). However, the purpose of an affidavit (and presumably a witness statement) is not merely disclosure at some point. An affidavit is created to present the deponent’s evidence to the court, in order to persuade the court to reach a particular conclusion on the facts. It is a clear exemplar of a persuasive document. Its preparation, drafting and constant redrafting are within the core conception of preparation for litigation. Inconsistent drafts may spell doom for the credibility of the deponent. Inappropriate phrasing may let in an own-goal. Affidavits should thus be prepared within the zone of privacy that is expected by the parties to the litigation, to enable each to prepare his or her own case without prematurely showing the hand that is to be played.

[emphasis added]

23 What this means is that an affidavit, or a written statement, being the evidence that a witness intends to present to the court, must be drafted with care and diligence. It bears emphasising that litigants are not prohibited from using generative AI: see Registrar’s Circular No. 1 of 2024 titled: “Guide on the Use of Generative Artificial Intelligence Tools by Court Users” (the “Guide”). But they must take responsibility for its output, especially where this is evidence that will be presented to the court. The very issue with using generative AI in the drafting of such documents is the temptation to rely entirely on the algorithm without applying one’s mind to the actual output.

24 Consequences must therefore follow where the court has reason to doubt whether a witness had indeed verified the contents of their affidavit or unsworn statement (as the case may be) which had been prepared with the assistance of generative AI. As I have explained, in the present case, I found that the appropriate recourse was to place no reliance on these written statements.

25 As a final and further point, I would add that there was no evidence to suggest that the Husband had misused generative AI to generate these voluminous statements in an attempt to overwhelm counsel for the Wife. That being said, the courts have always taken a strict stance against such tactics being deployed in litigation: see Mylward v Weldon [1596] EWHC Ch 1 (see also Standard Bank Plc v Via Mat International Ltd & Anor [2013] EWCA Civ 490 at [29]). It goes without saying that any such misuse of generative AI to overwhelm one’s opponent in litigation would certainly amount to conduct that the court can take into account in assessing costs.

SSP 698 – The Husband’s Application for a PPO, DEO, CGO, and MTO

26 I turn now to deal, first, with the Husband’s application in SSP 698.

27 In order to obtain a PPO, the Husband must establish the following two requirements on a balance of probabilities. That much is made clear by s 60A(1) of the Women’s Charter 1961 which applies to the present application.

28 First, the Husband must show that the Wife had either committed, or was likely to commit, family violence (as is defined in s 58B of the WC) against him.

29 Second, the Husband had to show that the protection order was indeed necessary for his protection or personal safety.

30 The Husband’s main allegation against the Wife, as set out in his complaint form, was that she had subjected him to emotional and/or psychological abuse. In summary, his case was that the Wife controlled him for more than a decade with the result that he was reduced to a pathetic and destitute state. It was only after he had applied to Ministry of Social and Family Development (“MSF”) for assistance in 2024, and after his application had been granted, that he was able to get back on his feet, and to throw off the shackles of living under his Wife’s yoke.

31 There were, to my mind, two main issues.

32 The first, was whether the Husband had indeed been reduced to, as he had claimed, a destitute state. The second was whether the Husband’s destitute state was the result of the Wife’s actions in depriving him access to food and money.

33 On the first point, a key plank of what the Husband said was evidence of his destitution was that he was severely malnourished. He claimed that because the Wife had deprived him of access to food, he did not have sufficient nutrition. As a result, his teeth had rotted, and his bones had become brittle. This necessitated trips back to India to fix his teeth, as he could not afford dental care in Singapore. This also meant that, when he had a short fall off a stool as he was trying to replace a lightbulb, he broke several bones.

34 I did not find that the Husband had proven that he was indeed in a destitute state.

35 For one, although the Husband had exhibited what he said was evidence of his malnourished state, I did not think that those pieces of evidence pointed to the conclusion that the Husband urged me to reach. These pieces of evidence were: a) his blood test results, b) the results of a dietary quiz, and c) the forms showing that he had been granted assistance by ComCare.

36 In relation to the blood test result, there was no doctor’s letter which stated that these blood test results showed that the Husband was indeed malnourished. Further, insofar as the Husband pointed to the results of the dietary quiz, there was no indication of how these results, which appeared to show that the Husband’s food intake was not optimal, were arrived at, nor was there any accompanying information stating whether the Husband had filled out the quiz on his own, or whether the quiz was administered by a healthcare professional.

37 Insofar as the Husband pointed to the fact that he had obtained assistance from ComCare, I too, did not find that this was necessarily indicative of his destitute state. All that the Husband had exhibited was a letter from MSF stating that they would be supporting him with cash payments of $520 per month for the period March 2024 – May 2024. Although the Husband had stated, in his testimony, how the relevant agencies had assessed his living situation, and approved his application for aid, the point was that he had not provided any evidence to corroborate his testimony. Absent such evidence, I could only infer, from the MSF letter that the Husband had exhibited, that the relevant agencies had assessed the Husband’s situation, determined that he was eligible for assistance, and extended that assistance to him. Beyond that, there was nothing on the evidence which shed light on the basis on which the Husband had obtained such assistance.

38 It bears emphasising, at this juncture, the golden rule of litigation, that he who asserts must prove their case: YCN and YCP v YCO [2026] SGFC 63 at [1] citing ss 103 and 104 of the Evidence Act 1893; Liu Shu Ming and anor v Koh Chew Chee and anor matter [2023] 1 SLR 1477 at [1]. In this regard, the Husband had not proven that he was indeed in such a destitute state. In this connection, I must add that on the Husband’s own evidence given at trial, it did not appear that he was indeed in such a destitute state.

39 For one, during the course of his testimony, the Husband had narrated how he would go out to buy flour. He told me that he would purchase flour in 5kg bags because they were the cheapest option available. He would purchase three of such bags and haul his entire purchase 1.2km back to his house. Given the load, the Husband would take breaks along the way.

40 The Husband’s narrative is difficult to believe. If he was indeed destitute, and left in such a state where he was so physically weak such that his bones had become brittle, and his teeth had rotted away, it was quite unlikely – even giving generous allowances for the resilience of the human body and the strength of the human spirit – that he would have been able to haul that quantity of flour, over that distance, all the way home.

41 Even taking the Husband’s case at its highest, and accepting that he was indeed destitute, the second issue was whether the Wife had, through the control she had allegedly wielded over him, put him into such a destitute state.

42 As a starting point, the Husband’s allegation that the Wife was responsible for his destitute state was premised on what he said was the level of control the Wife had exerted over him. He said that she had restricted his access to money, and food. He also said that she had weaponised the PPO which she had obtained against him in 2011. He said that he had only managed to break free from his Wife’s control in 2024, after he had applied to MSF for assistance.

43 I did not find that the Wife had exerted control over the Husband. The videos which the Husband had adduced are telling.

44 These videos appear to have been taken on 19 June 2022. The first video shows the Husband in the kitchen. He was making food. He says the Wife had threatened him to stop cooking in the kitchen. The Wife can be seen in the video. She looks at him, but remains silent. Throughout the video, the Husband can be heard making various allegations about what the Wife had done.

45 The second video shows the Husband filming in the kitchen. Again, he makes various allegations against the Wife, accusing her of depriving him of food, and of alienating him from his son. The Wife can also be seen filming him. Tellingly, the Husband threatens to haul the Wife to court, and that once he had been vindicated, he would call a press conference.

46 These two videos, taken together, provide a snapshot into the real dynamics between the Husband and the Wife. It can be clearly seen from the video that there was unlocked food in the refrigerator, and the Husband can be heard claiming that the Wife had put up notices saying that he could not touch the food. If it were truly the case that the Wife had exerted such control over him, such that a mere notice would suffice to stop him from taking food from the refrigerator, one would, quite reasonably, infer that he would behave in a meek and timid manner before his Wife.

47 That was not what the video showed. The Husband was clearly able hold his ground with a clear air of defiance. This was, quite evidently, not a man who lived under his Wife’s control.

48 This point was also amply made in another video adduced by the Husband which was dated 19 May 2023. The video clearly shows the Husband engaging in a heated quarrel with the Wife.

49 In my judgment, it is the Husband, and not the Wife, who was responsible for the destitute state that he found himself in.

50 First, it was evident to me, from the Husband’s own testimony, that his retrenchment in 2009 had severely impacted him, as well as his confidence. I accepted that he might have faced some difficulties in finding work. But it was also evident to me that he did not have healthy ways of coping and adjusting, and as a result, fell into a destructive spiral. For one, the Husband did not appear to have a strong support network. He had told me, in his testimony, that when he came to Singapore, his only friends were his colleagues from work. Once he lost his job, he became increasingly socially isolated as he felt too embarrassed to meet up with his friends for a coffee – this stemmed from his own perception that his friends would think that he was freeloading off them.

51 Second, I found that while the Husband might have had difficulties finding work, I thought those difficulties were, in all likelihood, exaggerated. The Husband has a number of qualifications, all in the field of business, to his name. He testified that he used to, prior to his retrenchment, work for a large American multinational firm. Given his background and experience, and even giving allowance for his personal struggles at the time, I found it difficult to believe that he was completely unable to find work at all, and as a result, remained unemployed for more than a decade.

52 It may be true that the Husband may have faced enormous difficulties finding work that provided the same remuneration and perks that he had enjoyed previously. But I considered it likely that he could have found some work all the same, especially taking into account his qualifications and work experience.

53 To sum up, I did not find that the Wife was responsible for the state that the Husband had found himself in. The evidence before me, as I have explained, did not show that the Wife had indeed controlled the Husband to such an extent that he became destitute. I considered it more likely than not that the Husband was responsible for his own predicament.

54 The conclusion I reached was that the Husband had not shown that the Wife had committed family violence on him. I would also add that I did not find it likely that the Wife would commit family violence on him. I accepted the Wife’s account that she wanted nothing more to do with the Husband. It was clear to me that she had shouldered the burden of running the household, and had only stayed together with the Husband for the sake of their son. Now that their son was grown up, she was making plans to leave the Husband, and to start life afresh.

55 Given that the Husband had not shown that the Wife had committed, or was likely to commit family violence on him – his application must fail. In any event, I also found that it was not necessary to grant a PPO in this case.

56 In assessing the necessity of granting a PPO, the court undertakes a risk assessment: XNY v XNZ [2025] SGFC 69 at [49] citing XFL v XFM [2024] SGFC 103 at [19] – [20]. There was, in my judgment, a low risk of the Wife committing family violence on the Husband in the future. For one, the Husband had, according to him, managed to break free of his Wife’s control with some assistance, and had taken steps to get back on his feet, and was, once again, looking for work.

57 Then there was also the Wife’s attitude towards the Husband, which was one of indifference. She did express a wish to cut ties with the Husband, and to that end, divorce proceedings were already well underway. The evidence thus showed that the Wife was set on parting ways for good with the Husband.

58 Taking all these points in the round, it was clear that there was a low risk of the Wife committing family violence on the Husband, and with that, it was indeed not necessary to order the PPO which the Husband sought. And given that the Husband’s application for a PPO had failed, so too must his applications for a DEO, CGO, and MTO.

SSP 699 – The Husband’s Application to Revoke the Wife’s PPO

59 I turn now to deal with the Husband’s application to revoke the Wife’s PPO in SSP 699.

60 The factors which the court must take into account in deciding whether a PPO should be varied, suspended or revoked are set out in s 60A(5) of the Women’s Charter 1961. That provision states:

(5) In deciding whether to vary, suspend or revoke a protection order, the court —

(a) must disregard any consent to the variation, suspension or revocation purportedly given by Y if there is reason to believe that the consent was not voluntarily given; and

(b) must consider —

(i) whether there has been any change in the circumstances that required the protection order to be made;

(ii) if a counselling order was made against X under section 60E(2) — any report by the person conducting the counselling or other programme that X is required to attend; and

(iii) if a mandatory treatment order was made against X under section 60F(2) — any report by the appointed psychiatrist.

61 There was a counselling order made when the Wife obtained her PPO against the Husband. The counselling report for the Husband was produced. In the usual course of things, such reports are, and would typically remain confidential. However, given that I had to consider the counselling report, one issue I had to decide was whether that report should be made available to both parties.

62 Having considered the matter, I had copies of the report extended to the parties so that they could, if they wished, make the relevant submissions on it. I considered that it was appropriate to do so, giving weight to the fact that if that report was to be taken into account, then it was only fair that parties be provided with a copy so that they were in a position to make any relevant arguments.

63 Given that the Husband was applying to revoke the PPO, he bore the burden of proving that there had been a change in circumstances that would justify doing so. In other words, the Husband had to show that the PPO was no longer necessary for the Wife’s protection.

64 I did not find that the Husband had proven that the PPO ought to be revoked. Rather, I found that the PPO still remained necessary. Although the counselling report indicated that the Husband had, apparently, made progress because he had, amongst other things, learnt his lesson to not inflict family violence on the Wife, and that he would be more mindful and respectful of boundaries at home, I would place very little weight on the findings of the report. The report, after all, was produced more than a decade ago. The present circumstances that I have found before me, however, did point towards keeping the PPO in force.

65 For one, it was clear that the Husband remained antagonistic towards the Wife. He blamed her for, amongst other things, alienating him from his son, and having controlled his life for more than a decade. Further, the both of them still continued to share the same space as they still live together in the same flat. Finally, it was also clear to me that their divorce was an acrimonious one.

66 Taken together, the Husband’s perception of the Wife, coupled with their present living arrangements and the ongoing divorce all pointed towards the continued risk of the Husband inflicting family violence on the Wife.

67 For these reasons, I dismissed the Husband’s application in SSP 699 to revoke the PPO.

Conclusion

68 Given that both the Husband’s applications in SSP 698 and 699 were dismissed, on the issue of costs, Mr Gill argued that costs should be fixed at $30,000 (all-in).

69 The Husband, on the other hand, argued that there should not be any order as to costs. He said that the Wife had “put in a lot of irrelevant things”. He also claimed that the Wife had a “history of being vexatious” and that she had tried to deny his right to be heard.

70 The rules on costs are straightforward. Costs shall follow the event:
P 22 r 3(2) of the FJ(G)R 2024. In the present case, the Wife has succeeded in her application, so, as a starting point, she was indeed entitled to costs.

71 I saw no reason to depart from this starting point. Taking into account, amongst other things, the length of the trial, the volume of documents which had been submitted, I fixed costs at $10,000 (all-in). I ordered that this amount be paid by the Husband to the Wife by 26th November 2025.

72 In addition to costs, I also ordered that the Husband do the following in respect of the divorce matter – that was, if he should use generative AI to assist him in preparing any document filed in respect of the divorce matter, he was to declare such use to the court, that he had complied with the Guide, and that all the contents of the documents he had submitted were true and accurate.

Soh Kian Peng
Magistrate

Jagjit Singh Gill S/O Harchand Singh (Gurdip, Gill & Sew) for the Wife;

The Husband in person and unrepresented.