1 This judgment decides the ancillary matters arising from the dissolution of the parties’ marriage. The plaintiff (“Wife”) aged 54, is a director at a government ministry. ¹ The defendant (“Husband”), aged 51, is a businessman. ² He is a director and the majority shareholder of [Company B], ³ a wildlife management and pest control company founded by his father in or around 1981. ⁴ The parties were married on 20 October 2001. ⁵ The Wife commenced divorce proceedings on 18 January 2024, ⁶ and interim judgment (“IJ”) was granted by consent on 8 July 2024 (“IJ date”). ⁷ The parties have a child (“Child”) who is 23 years of age. ⁸

2 The issues of custody, care and control of and access to the Child, as well as the Child’s maintenance, were resolved by the parties in a consent order recorded in the IJ. ⁹ The parties have also agreed that there will be no maintenance for the Wife. ¹⁰ This judgment therefore concerns only the division of the matrimonial assets and costs.

3 The parties are in agreement that the pool of matrimonial assets is to be identified as at the IJ date (ie, 8 July 2024), and that the assets are to be valued as at the date of the ancillary matters hearing (ie, 27 April 2026), save for the balances in bank accounts and CPF accounts, which are to be valued as at the IJ date. ¹¹ This accords with the default position stated in CVC v CVB [2023] SGHC(A) 28 at [55], and I adopt it.

4 The only asset held in the parties’ joint names is the parties’ matrimonial home (“Matrimonial Home”). Its inclusion in the matrimonial pool is not disputed. The parties agree that its net value is S$1,477,552.21, being the agreed gross value of S$2,600,000 less the outstanding mortgage of S$1,122,447.79 as at 1 November 2024. ¹²

5 I turn to the assets held in the Wife’s sole name. The parties concur on the inclusion and value of all but two of the Wife’s assets. The two exceptions are the Mazda3 motor car (“Car”) and the Citibank Investment Fund Account No. -6342 (“Citibank Investment Fund Account”). I set out the full list of the Wife’s assets at [20] below, and address the Car at [6] and the Citibank Investment Fund Account at [7]–[19].

6 The parties accept that the Car falls within the matrimonial pool but dispute its value. ¹³ The Wife values the Car at S$25,881 as at 31 August 2025, ¹⁴ while the Husband values it at S$33,188 as at 6 October 2024. ¹⁵ Both figures are derived from listings on the online marketplace (sgcarmart.com) for vehicles of the same model. ¹⁶ At the ancillary matters hearing, counsel for both parties agreed to adopt the midpoint of their respective figures. ¹⁷ I therefore adopt the average of the parties’ figures, and value the Car at S$29,534.50.

7 The parties’ common position is that the Citibank Investment Fund Account was worth S$53,206.24 as at 31 July 2024. ¹⁸ The dispute relates to whether it forms part of the matrimonial pool. The Wife submits that the moneys are traceable to a S$100,000 gift from her mother and should be excluded from the matrimonial pool. ¹⁹ The Husband contests this, contending that the source of the alleged gift is unclear and, in any case, it has lost its character as a gift due to co-mingling. ²⁰

8 Under s 112(10) of the Women’s Charter 1961 (2020 Rev Ed) (“Women’s Charter”), an asset acquired by gift or inheritance is excluded from the matrimonial pool, unless it is the matrimonial home or has been substantially improved during the marriage by the other spouse or both spouses.

9 The party asserting that an asset was acquired by gift must establish that the asset is traceable to the original gift (CLC v CLB [2023] 1 SLR 1260 (“CLC v CLB”) at [65]). If the asset cannot be traced, it is “logically impossible” to ask whether the asset could nonetheless be a gift (CLC v CLB at [60]), and it cannot be excluded from the matrimonial pool on this basis.

10 In CLC v CLB at [72], the Court of Appeal held that the party asserting a gift must “adduce sufficient evidence to show linkage between a currently owned asset and an asset acquired by gift or inheritance”. For moneys in bank accounts, the evidence “could include details on the source of contributions into the account as well as the specific use of the withdrawals”. The tracing exercise is not “meant to be overly complicated or burdensome”, but each “link in the chain” required to trace the gift into the currently owned asset must be established, on “a common sense approach to tracing dependent on sufficient linkage between a non-matrimonial asset and an asset existing at the time of divorce” (CLC v CLB at [74]). Tracing may be defeated by co-mingling of matrimonial assets and assets acquired by gift such that the gift is no longer identifiable (CLC v CLB at [76]).  

11 The Wife’s account of the provenance of the moneys is as follows: ²¹

(a) Her father passed away in mid-2020, leaving his savings of about S$2m to her mother. On 10 December 2020, her mother gifted her S$100,000 by cheque, which was deposited into the Wife’s OCBC 360 Account No -4001 (“OCBC 360 Account”).

(b) Separately, and around the same time, the mother wished to take advantage of a Citibank promotion for “new-to-bank” customers. However, she already held a Citibank account herself. She, therefore, asked the Wife to open a Citibank Wealth First Account No -1339 (“Citibank Wealth First Account”) into which the mother’s S$2m inheritance was deposited on 17 December 2020.

(c) On 4 February 2021, the Wife transferred the S$100,000 from the OCBC 360 Account into the Citibank Wealth First Account by cheque. On 5 February 2021, she applied it towards the purchase of investment funds held under the Citibank Investment Fund Account. On the same day, the Wife also invested, on her mother’s instructions, her mother’s S$2m in specified funds under the same account.

(d) On 10 February 2022, all of the mother’s investment holdings and the dividends earned on those investments were transferred out to the mother’s own Citibank account. The moneys that remain in the Citibank Investment Fund Account are thus the residue of the Wife’s S$100,000 gift, valued at S$53,206.24 as at 31 July 2024.

12 I find that the Wife has established each step in the chain of events from the time she received the S$100,000 gift to the moneys now in the Citibank Investment Fund Account. Each of the steps at [11(a)]–[11(d)] is supported by contemporaneous bank records – there are bank statements recording the 10 December 2020 deposit, ²² the transfer of S$2m by cheque into the Citibank Wealth First Account on 17 December 2020, ²³ the transfer of the full S$100,000 on 4 February 2021 into the Citibank Wealth First Account, ²⁴ the purchase of the investment funds the following day, ²⁵ and the eventual return of the mother’s investment holdings and dividends. ²⁶ The S$2m transfer from the Wife’s mother to the Wife is also supported by a cheque dated 17 December 2020 evidencing the transfer of S$2m from one “Elizabeth Low” and “Charissa Tan” into the Citibank Wealth First Account. ²⁷ I further find that the S$2m in the Citibank Wealth First Account belonged to the Wife’s mother. The Wife’s account that she was holding and investing the sum on her mother’s behalf is supported by the subsequent return of the full amount together with all dividends earned to the mother’s own Citibank account. As to the source of the gift, although the Husband argues in written submissions that the Wife did not adduce any evidence of the S$100,000 cheque from her mother, ²⁸ his counsel, Mr Johnson Loo (“Mr Loo”), accepted at the hearing that the Husband did not have any positive evidence that the S$100,000 came from any other source. ²⁹ The Wife’s account of the provenance of the moneys in the Citibank Investment Fund Account is therefore uncontradicted and supported by contemporaneous documents and, accordingly, I accept her evidence.

13 The Husband further argues that even if there was a S$100,000 gift, the Wife cannot trace it to the moneys now in the Citibank Investment Fund Account, because the gift was co-mingled along the way. ³⁰ He makes three points. First, on the Wife’s own account, the S$100,000 was deposited into the OCBC 360 Account, where it was mixed with other funds such as her salary, before being transferred to the Citibank Wealth First Account. ³¹ The sum withdrawn from the OCBC 360 Account in February 2021 may therefore not be the same S$100,000 that her mother gave her in December 2020. ³² Second, the investments purchased through the Citibank Wealth First Account totalled some S$1,585,000, far exceeding the S$100,000 said to have been gifted. ³³ Third, it is in any event unclear whether the investments held in the Citibank Investment Fund Account as at the IJ date are the same as those purchased in February 2021. ³⁴ I address these three points in turn.

14 Regarding the first point that the S$100,000 cheque from the Wife’s mother was deposited into the Wife’s OCBC 360 Account and mixed with her salary before being transferred out, such that the sum withdrawn may not be the same S$100,000 her mother gifted her in December 2020, the Husband is correct insofar as this was a mixing of the gift with matrimonial assets (as the Wife’s own position is that the OCBC 360 Account is a matrimonial asset). ³⁵ However, I do not accept that this constitutes co-mingling that defeats the tracing of the S$100,000 gift.

15 It is not the position in law that the mere placing of a gift into a bank account which is a matrimonial asset renders the gift no longer traceable. As the Court of Appeal made clear in CLC v CLB at [76], the co-mingling of matrimonial assets and assets acquired by gift “in a bank account does not in itself mean that the latter type has ceased to retain its character as a gift or inheritance as such, although it is likely to make the task of tracing more difficult”. The Court of Appeal’s framing of the consequence of co-mingling as a matter of tracing being “more difficult” confirms that the inquiry ultimately rests on the identifiability of the gift. Here, the Wife transferred the full S$100,000 from the OCBC 360 Account to the Citibank Wealth First Account about two months after receiving it. The sum, in my view, remained identifiable despite its temporary deposit into an account containing matrimonial funds.

16 I am fortified in this view by a comparison with the cases in which co-mingling did defeat tracing. In MacLean v MacLean [2019] NSJ No 554 (cited in CLC v CLB at [72]), the Nova Scotia Supreme Court held that the husband failed to establish that inheritance monies in a bank account should be returned to him, because there was no detailed accounting of the account. Moneys had been deposited from various sources including the parties’ joint account, the balance at times fell below the amount of the inheritance, and there were numerous withdrawals over the years without any accounting for their application, thus it was impossible to say the inheritance had survived intact. None of that happened here. It is not argued by the Husband, neither do the bank records show, that the balance in the OCBC 360 Account fell below S$100,000 between the deposit and withdrawal. There is also no evidence that the gift was spent during this period. The present facts fall rather on the side of Laskosky v Laskosky [1999] AJ No 131 (cited in CLC v CLB at [73]), where the Alberta Court of Queen’s Bench accepted that inheritance funds placed in a joint account and applied to purchases “made immediately or not long after the funds became available” had been sufficiently traced. On a common-sense approach to tracing (CLC v CLB at [74]; see above at [10]), I am satisfied that the temporary repose of the gift in the OCBC 360 Account is not a mixing of a kind or duration that defeats the traceability of the S$100,000 gift.

17 The Husband’s second argument that the investments purchased totalled some S$1,585,000, far exceeding the S$100,000 said to have been gifted, also does not assist him. The reason the total sum invested exceeded S$100,000 was because the S$2m owned by the Wife’s mother was invested through the same account. Any mixing was therefore of the Wife’s gift with her mother’s moneys (ie, those of a third party), and not with any matrimonial asset. The core concern underlying co-mingling is that where a gift is mixed with matrimonial moneys, it may become difficult to ascertain how much of the resulting asset remains the excluded gift and how much is the divisible matrimonial portion. The question is ultimately one of identifiability of the gift (CLC v CLB at [76]). This concern does not arise from mixing the Wife’s gift with her mother’s money. There is no matrimonial share from which the gift must be disentangled, and hence no question of identifiability against the matrimonial pool.

18 As to the Husband’s third point that it is unclear whether the investments held at the IJ date are the same as those purchased in February 2021, the Wife provides documentary evidence that she had purchased four funds using her mother’s S$2m and her S$100,000 gift in February 2021: the First Sentier Bridge Fund, the BGF China Bond Fund, the Eastspring IUT-Singapore Select Bond Fund and the Fidelity Global Multi Asset Income Fund. ³⁶ As at 31 July 2024, the date the parties agreed to value the account, it held three of those same four funds: the First Sentier Bridge Fund, the Eastspring IUT-Singapore Select Bond Fund, and the Fidelity Global Multi Asset Income Fund. ³⁷ I further note that the number of units held in each of the three remaining funds as at July 2024, being 17,192.12 units in the First Sentier Bridge Fund, 13,055.062 units in the Eastspring Fund, and 19,291.34 units in the Fidelity Fund, match precisely the number of units purchased by the Wife on 5 February 2021 using the S$100,000 gift. ³⁸ Most of the original investments are therefore still in the account, and there is nothing to suggest that additional funds were injected into that account. Specifically, there is no evidence, nor is it the Husband’s argument, that the Husband paid any moneys into the Citibank Investment Fund Account, or that the Wife mixed the gift in that account with any moneys of her own. On the evidence before me, the Citibank Investment Fund Account only ever held the mother’s S$2m and the Wife’s S$100,000 gift. Once the mother’s holdings and their dividends were transferred out on 10 February 2022, what remained could only be the residue of the S$100,000 gift.

19 In light of the above, I find that the sum of S$53,206.24 in the Citibank Investment Fund Account as at 31 July 2024 is traceable to the original S$100,000 gift and is accordingly excluded from the matrimonial pool.

20  Taking into account the assets addressed above, together with the Wife’s undisputed assets, the following assets in the Wife’s sole name are added to the matrimonial pool:

21  I turn to the assets in the Husband’s sole name. Three assets are in dispute: the DBS Account No -503-7 (“DBS Account”), the Honda Supra GTR 150 Motorcycle (“Motorcycle”) and the 40,000 shares in [Company B] (“[Company B] Shares”). The Wife also seeks to add back into the pool three sums which the Husband is said to have expended: rental payments of S$180,994, transfers of S$128,116 to the Husband’s alleged new partner (“Alleged Partner”), and legal fees of S$29,300.36. I address the DBS Account at [22]–[23], the Motorcycle at [24], the [Company B] Shares at [25]–[79] and the sums the Wife seeks to add back into the pool at [81]–[98].

22  The parties agree that the moneys in the DBS Account fall into the matrimonial pool, but they disagree on the value of the account. The Wife values the DBS Account at S$43,281.37, while the Husband values it at S$14,623.06. ³⁹ Both figures are drawn from the same bank statement produced by the Husband. ⁴⁰ The Wife takes the balance as at 8 July 2024, ⁴¹ the IJ date, while the Husband takes the balance as at 31 July 2024. ⁴²

23 At the ancillary matters hearing, Mr Loo accepted that the Wife’s figure ought to be taken, consistent with the parties’ agreement that bank balances are to be taken as at the IJ date, and that the reliance on the 31 July 2024 figure had been an error on the Husband’s part. ⁴³ Accordingly, the DBS Account is valued at S$43,281.37.

24 The Wife values the Motorcycle at S$8,300 and the Husband values it at S$5,000. ⁴⁴ At the hearing, counsel accepted the midpoint of their respective figures as they had done for the Car. ⁴⁵ I therefore value the Motorcycle at the average of the two figures, S$6,650.

25 The parties dispute whether the [Company B] Shares fall within the matrimonial pool and, if so, the value to be ascribed to them. For the reasons given below, I find that the [Company B] Shares fall outside the pool. The question of valuation of the shares therefore does not arise.

26 The parties’ positions may be summarised briefly. The Husband’s case is that the [Company B] Shares were gifts from his parents which the Wife has not substantially improved. They are therefore excluded from the matrimonial pool. ⁴⁶ The Wife’s case is that the [Company B] Shares were acquired during the marriage and were not gifts. Even if they were gifts, they fall into the pool by reason of the Husband’s co-mingling of [Company B]’s funds with his personal accounts, the Husband’s intention to deal with the shares as part of the family estate, and/or the Wife’s substantial improvement of the shares during the marriage. ⁴⁷

27 The following questions therefore arise for my determination. First, whether the [Company B] Shares were acquired by gift. Second, if so, whether they are no longer traceable as gifts by reason of the Husband’s co-mingling of [Company B]’s funds with his personal accounts. However, if they remain traceable, whether they have nonetheless been transformed into matrimonial assets by: (a) the Husband’s intention to deal with them as part of the family estate; or (b) the Wife’s substantial improvement of them during the marriage.

28 In support of his case that the [Company B] Shares were gifts from his parents, the Husband provides the following evidence. [Company B] was founded by his father in or around 1981. ⁴⁸ By 1984, the Husband’s father and mother held 20,000 and 10,000 shares in [Company B] respectively. ⁴⁹ His mother was never involved in the company’s operations. ⁵⁰ The Husband joined [Company B] in or around 2003, at his father’s suggestion, and from 2006 he and his parents began planning the succession of the business as his father prepared to retire from active management. ⁵¹ Pursuant to that plan, the Husband’s present 40,000 shares came to him in three tranches: ⁵²

(a) In 2007 or 2008, his mother transferred 10,000 shares to him without consideration.

(b) In 2008, [Company B] allotted 20,000 new shares. The Husband received 15,000 shares and his father received 5,000 shares. The allotment was funded by S$20,000 that his mother had injected into the company around 2006. Father and son then each held 25,000 shares.

(c) In 2017, his father transferred a further 15,000 shares to him. His father was then 72 years old and had retired from the management of [Company B]. The Husband consequently held 80% of [Company B]’s shares.

29 I am satisfied that the [Company B] Shares were gifts from the Husband’s parents. The Husband’s account of the origin of the [Company B] Shares is corroborated by objective and contemporaneous documents. He adduced the ACRA records of the transfers and allotment, ⁵³ [Company B’s] Memorandum and Articles, ⁵⁴ the 1984 annual returns, the director’s resolution for the 2008 allotment, ⁵⁵ the audited financial statements for 2006 to 2009, ⁵⁶ and the IRAS certificate of stamp duty for the 2017 transfer of shares. ⁵⁷ The Wife does not dispute this documentary evidence.

30 Her objection is directed instead at the three affidavits filed by the Husband’s parents and [Company B]’s long-serving Finance Manager, which set out the history of the company and the succession planning for the Husband to take over the business. ⁵⁸ She submits that little or no weight should be placed on these affidavits. ⁵⁹ The Finance Manager and the Husband’s mother were said to be too closely aligned with the Husband to be independent and, the father, with whom the Husband allegedly had longstanding conflicts, was concerned only to preserve the family business rather than to make a personal gift to the Husband. ⁶⁰

31 These challenges are meritless. The Wife did not adduce any positive evidence to contradict the accounts in the affidavits. Her case rests on bare assertions as to their supposed loyalties and relationships. Even if the Husband and his father had a difficult relationship, and even if the parents were motivated by a wish to keep the business within the family, I do not see how either is inconsistent with the shares being gifts to the Husband.

32 The Wife’s remaining argument is that the court must distinguish between a gift, being a voluntary transfer made out of personal generosity, and a transfer effected as part of succession planning, being a structured reorganisation of ownership for the continuity of a family business. ⁶¹ She relies on the conditional character of the arrangement (the Husband was to take over only if he wished to and was able), ⁶² the father’s stated reason for the 2017 transfer (that he was “already 72 years old and [had] not been involved with [Company B] for years”), ⁶³ the staggered nature of the transfers and allotment across 2007 to 2017, ⁶⁴ and the father’s retention of 10,000 shares to this day, ⁶⁵ as indicia of a succession plan rather than a “gratuitous conferment of personal benefit”. ⁶⁶

33 It is difficult to follow the logic of this argument. It is well-accepted that a valid gift inter vivos requires an intention to give and delivery of the subject matter of the gift (see for eg, Toh Eng Tiah v Jiang Angelina [2021] 1 SLR 1176 at [52]). Whether the transfers were motivated by the parents’ desire to pass the family business to the next generation does not displace the donative intent. In fact, the wish to keep the family business in the Husband’s hands reinforces the parents’ intention to gift the [Company B] Shares to the Husband. Whether the transfer of shares was staggered, or whether there were “conditions” to taking over the business (such as him being willing to do so) are likewise irrelevant to the inquiry of donative intent. On the evidence, I find that the [Company B] Shares were acquired by gift from the parents to the Husband.

34 The Wife further argues that even if the [Company B] Shares were gifts by the Husband’s parents, they have become matrimonial assets because the Husband co-mingled his personal funds with [Company B]’s funds. ⁶⁷ The Wife’s written submissions on this issue are not clear. She makes broad arguments with no supporting legal authorities to assist the court. Nevertheless, I understand her arguments to culminate in three points:

(a) First, the Husband ran [Company B]’s finances through his own account. On his own evidence, he drew credit facilities from several banks in his personal capacity, through his personal DBS Account, to fund [Company B]’s operating expenses. ⁶⁸ The Wife “question[s] the validity of the credit lines/credit facilities that the Husband took for [Company B]”, and “finds it unclear” why business expenses were channelled through his personal DBS Account rather than [Company B]’s own corporate accounts. ⁶⁹ She submits that the absence of documentary substantiation, coupled with the use of personal banking facilities for company expenses despite the availability of corporate credit lines, gives rise to “legitimate questions regarding the nature and propriety of these transactions”. ⁷⁰

(b) Second, the Husband used his personal DBS Account, into which his salary was paid and from which the mortgage and his personal expenses were met, for [Company B’s] expenditure. ⁷¹ She gives several examples – a [Company B] employee’s transfer of S$700 to the Husband’s DBS Account, which the Husband claims was from that employee’s sale of a client’s belongings; the Husband’s withdrawal of S$1,000 from the DBS Account to settle a private accident involving [Company B]’s van; a deposit of S$143,500 into the Husband’s DBS Account which he claims was for [Company B]’s expenses, but he withdrew only S$142,500, the S$1,000 difference being, she says, applied to his personal expenses; and a S$7,000 deposit which the Husband claims was for [Company B]’s operating expenses but it was withdrawn the same day for loan repayment. ⁷² In particular, the Wife argues that it is unclear why funds meant for [Company B] were routed through his personal account to repay his own facility, and notes that these movements do not appear in the records of payments between the Husband and [Company B] that he claims to keep. ⁷³

(c) Third, the Husband’s accounting was internally inconsistent. Sums he admits were loans from him to [Company B] appear in the company’s accounts as “Business” or “Operating Expenses” rather than as liabilities owed to him, which the Wife says cast doubt on whether the accounts accurately reflect the company’s financial position. ⁷⁴ She also argues that the interest and bank charges on his personal facilities were treated inconsistently. ⁷⁵ [Company B] reimbursed him for them as part of repayment of his loans, yet he recorded them as sums he owed back to the company, on the footing that they were his personal liabilities. ⁷⁶ She submits this is incoherent, since interest on borrowings drawn for [Company B]’s benefit should be the company’s financing cost, not his personal liability. ⁷⁷

35 The Husband accepts that he did not keep his personal finances and corporate finances entirely separate. He explains that it was easier for him to obtain credit personally rather than for [Company B], as an SME, to do so. ⁷⁸

36 At the hearing, I directed counsel to address the legal effect of co-mingling personal and corporate funds on gifted shares. ⁷⁹ Mr Loo highlighted the case of XIB v XIA [2025] SGHCF 40 (“XIB v XIA”), particularly [50]: ⁸⁰

37 From this passage, Mr Loo submits that co-mingling can defeat the traceability of a gift only where the gifted asset itself is mixed with other assets and can no longer be identified. ⁸¹ He says that because the gift here is the [Company B] Shares, and the shares themselves were never mixed with anything and remained a distinct identifiable asset throughout, they remain a gift and fall outside the matrimonial pool. ⁸²

38 But XIB v XIA does not stand for that proposition. In that case, the husband was the sole shareholder of a company he had owned before the marriage, and he had used moneys from his personal bank accounts to pay the company’s foreign suppliers. The District Judge had included the shares in the matrimonial pool, treating the husband’s use of personal funds for the company as having transformed them into a matrimonial asset. On appeal, Mohamed Faizal JC (as he then was) rejected that approach, on the basis that it would dilute the test for substantial improvement (see above at [36]). Thus, XIB v XIA only decides that the co-mingling of personal funds and company funds ought not to be taken as a substantial improvement of the company’s shares, for the reason that a rule to the contrary would draw nearly every small family company into the matrimonial pool given how commonly owners blend their personal and company finances. It does not decide, as Mr Loo claims, whether the co-mingling of personal and company funds defeats the traceability of gifted shares.

39 In my view, however, the proposition that Mr Loo advances is necessarily correct. The Court of Appeal in CLC v CLB has made clear that tracing an asset to one acquired by a gift is a question of identifiability (CLC v CLB at [65]–[67] and [76]). The Wife’s complaint ultimately concerns the mixing of personal and corporate funds, but she has not established that this affected the character of the shares as gifts. The difficulty with the Wife’s argument is that on the present facts the gift is the 40,000 [Company B] Shares whereas the mixing the Wife describes is of the Husband’s personal funds with the company’s funds. The [Company B] Shares are not part of that mixture. They are a distinct asset, registered in the Husband’s sole name, and they remain so however the Husband handled [Company B]’s cashflow, and however loosely he segregated the company’s money from his own. In other words, I do not see how the lack of segregation between the Husband’s personal and corporate funds can give rise to any question as to the identifiability of [Company B’s] Shares.

40 The Wife relies, in her supplementary submissions, on WJF v WJE [2023] SGHCF 17 (“WJF v WJE”) at [6], where Choo Han Teck J held that the husband’s withdrawals from the company’s bank balance diminished the value of the company shares: ⁸³

41 Based on the passage above, the Wife argues that by the Husband’s treatment of the funds of [Company B] as his own, the [Company B] Shares have been transformed into a matrimonial asset. This reading takes the above passage out of context. In WJF v WJE, the District Judge below had drawn an adverse inference against the husband because he had not adduced sufficient evidence distinguishing moneys applied for company purposes from moneys applied for his own domestic uses. Importantly, the husband’s shares in the company were already accepted to be matrimonial assets. On appeal, the husband only disputed the addition of sums he had withdrawn from one of his companies, arguing that the company’s assets were not matrimonial assets because the company was a separate legal entity. Choo J rejected this argument at [6] (see above at [40]), reasoning that while the company’s assets were not matrimonial assets, the husband’s shares were, and those shares had been valued by reference to the company’s bank balance. The husband’s withdrawals had therefore “improperly diminished the value of the shares”, and adding the withdrawn sums back thus simply restored the shares to their true value; there was no need to pierce the corporate veil. WJF v WJE therefore does not at all stand for the proposition the Wife advances that the mixing of personal moneys with company funds somehow “transforms” the company shares into a matrimonial asset.

42 The Wife has not, in either her written or oral submissions, asked the court to draw such an adverse inference against the Husband, nor to add back to the matrimonial pool the sums he spent on [Company B]. The latter approach was taken in XIB v XIA, where Faizal JC had added back to the pool the personal moneys the husband had spent on his company. The basis for doing so was that those moneys were themselves matrimonial assets, and a spouse who spends matrimonial money on a pre-marriage asset (the husband there had been the sole shareholder of the company prior to the marriage) must return the equivalent to the pool (XIB v XIA at [56], applying USB v USA at [19(c)]).

43 On the present facts, even if the Husband used matrimonial funds to pay the interest and bank charges incurred for [Company B]’s benefit, there is insufficient evidence to establish the amount, if any, that should be restored to the matrimonial pool. The Wife has also not identified or quantified any sum to be added back. I therefore make no adjustment.

44 I find that the Husband’s co-mingling of personal and corporate funds did not affect the traceability of the [Company B] Shares. Accordingly, the shares retain their character as gifts.

45 The Wife submits in supplementary written submissions that the Husband’s treatment of [Company B]’s funds as his own shows an intention to treat the shareholding as part of the marital estate. ⁸⁴ I note that the Wife did not advance this argument in her written submissions or at the hearing, but I address it for completeness.

46 An asset acquired by gift may enter the matrimonial pool where the donee spouse evinces a real and unambiguous intention to deal with the asset as part of the family estate (CLC v CLB at [64]). To assess whether the Husband’s treatment of [Company B]’s funds suffices to show such an intention, it is useful to consider what conduct the authorities have held to suffice.

47 In CLC v CLB, the requisite intention was found where the husband: (a) placed the gifted moneys and inheritance moneys into a joint account operable by the wife, giving rise to a rebuttable presumption of an intention to share; (b) described those moneys in correspondence as “Our Net Worth”, “our liquid assets” and “our net wealth”, presenting them as the couple’s total wealth as opposed to his private assets; and (c) applied the moneys to the family’s benefit, including the purchase and renovation of properties. On the evidence, the Court of Appeal found that the husband demonstrated a clear and unambiguous intention that the inheritance moneys were to be part of the family estate (CLC v CLB at [88]–[96]). In AAE v AAF [2009] 3 SLR(R) 827, the husband’s registering of his wife as a joint tenant of a property purchased with the proceeds of a gifted asset strongly evinced his intention to treat proceeds of the gift as a matrimonial asset (cited in CLC v CLB at [63]). In both cases, the donee spouse took a positive and unequivocal step, through words and/or conduct, that dealt with the gift itself as a shared asset.

48 The present case is, in my view, different. The Husband used his personal accounts to manage [Company B]’s finances. He also obtained personal credit facilities to fund its operations. However, these transactions concerned the company’s funds, not the shares. There is no evidence that the Husband treated the shares as jointly owned or otherwise intended to share them with the Wife. I therefore find that he did not demonstrate a real and unambiguous intention to treat the shares as part of the family estate.

49 Additionally, the reasoning of Faizal JC in XIB v XIA at [50] (see above at [36]) is equally applicable here. If the mere absence of separation between personal and corporate funds were treated, without more, as evidence of an intention to bring the shareholding into the family estate, the requisite intention would be found in virtually every case involving a small family company, and such companies would fall into the matrimonial pool as a matter of course. I do not think that fulfils the clear and unambiguous intention that the law requires.

50 As mentioned above at [8], an asset acquired by gift or inheritance may be transformed into a matrimonial asset if it has been substantially improved during the marriage by the other spouse or by both spouses (s 112(10) of the Women’s Charter).

51  The Wife’s alternative case is that she substantially improved the [Company B] Shares during the marriage, thereby transforming them into matrimonial assets. She contends that she did so in two ways: first, through her homemaking and caregiving, which she undertook after giving up full-time employment for part-time work, and by bearing the greater share of household and the Child’s expenses; and second, through the loans she extended to the Husband for [Company B]. ⁸⁵ She says that taken together, these contributions enabled the Husband to focus on building [Company B] into the successful company it is today. ⁸⁶ The Husband disputes this. He argues that the Wife was never involved in running [Company B] and that substantial improvement requires both an investment of money or money’s worth in the asset and a direct causal link to its improvement. ⁸⁷ These are, on his case, requirements that neither her domestic contributions nor her loans can satisfy. ⁸⁸

52 To understand the parties’ respective arguments, it is helpful to set out the background facts, much of which are not in dispute.

53 The Husband joined [Company B] in 2003, two years into the marriage. At the time, it was a small, one-man operation that ran at a loss, had no physical office and possessed virtually no assets. ⁸⁹ This was according to a contemporaneous report adduced by the Wife, which documented the company’s growth since the Husband took over [Company B]. ⁹⁰ The Husband does not dispute the report. ⁹¹ As the Husband worked to grow the company, its revenue increased but so did its costs, and it came under mounting cashflow pressures as it expanded. ⁹² In fact, the Husband did not draw a regular salary from [Company B] until June 2021, receiving only ad hoc director’s fees prior to that. ⁹³

54 Today, [Company B] is a successful business. By 2005, its annual turnover had quadrupled to over a quarter of a million dollars. ⁹⁴ By 2018, it had achieved an annual revenue of over S$2m, engaged more than 30 employees, and operated out of two offices in Singapore. ⁹⁵ On the parties’ respective expert valuations, the Wife’s expert values the [Company B] Shares at more than S$2.9m, ⁹⁶ while the Husband’s expert values them at between S$1.3m to S$1.5m. ⁹⁷ Whatever the precise value, both valuations plainly reflect a company that has grown substantially in value. There is no doubt that [Company B] and its shares have improved substantially.

55 The Wife alleges that she had substantially improved [Company B]. As the Husband did not have a stable income when he first joined [Company B], she shouldered most of the household expenses, the greater share of the home loan and most of the Child’s expenses. ⁹⁸ She transitioned from full-time to part-time employment for 13 years to care for the Child without the aid of a domestic helper, and attended to the Husband’s needs as well. ⁹⁹ Beyond her contributions at home, she supported the Husband in his business endeavours by lending a listening ear, offering perspectives and suggestions, and providing encouragement. ¹⁰⁰ She also helped to clean and set up his new office premises, brought food to his office, and purchased items for his workspace. ¹⁰¹

56 These financial and non-financial contributions by the Wife are undisputed by the Husband. I accordingly accept that she made these contributions as she describes.

57 It is also undisputed that over the course of the marriage, the Wife had loaned moneys to the Husband for the purposes of [Company B]. As [Company B]’s cashflow difficulties worsened, the Husband had in 2012 exhausted his personal loan and credit card facilities in funding the business. ¹⁰² When he could meet only the minimum sums of repayment, the banks cancelled his facilities and sued him on two debts. ¹⁰³ He settled one debt himself and the Wife extended a loan of about S$15,981.96 to him to repay the other debt (“2012 Loan”). ¹⁰⁴ The existence and quantum of the 2012 Loan are accepted by both parties.

58 For some years after, the Husband could not obtain credit and borrowed more sums from the Wife. ¹⁰⁵ The parties, however, disagree on the quantum of these additional loans. The Wife provides documentary evidence showing that between then to 2021, she made more than 15 transfers of moneys to the Husband, totalling about S$213,000. ¹⁰⁶ She says these were all loans made for the purposes of [Company B], to meet expenses such as staff salaries, CPF payments, and the purchase of equipment or supplies. ¹⁰⁷ The Husband’s claim is that the Wife only made three loans to him for [Company B] in 2019 totalling about S$58,000, in addition to the 2012 Loan. ¹⁰⁸ He says that the other transfers were for other purposes such as mortgage payments. ¹⁰⁹

59 It is unnecessary for me to resolve the precise quantum of the Wife’s loans to the Husband for [Company B]. It suffices that both parties accept that she lent him significant sums, in particular the 2012 Loan, over the course of the marriage to support the business. There is also no dispute that the Husband has repaid all the relevant loans to the Wife. The Husband says he has done so, ¹¹⁰ and the Wife does not allege that any sums remain outstanding.

60 The key question before me, therefore, is whether these financial and non-financial contributions by the Wife amount to a substantial improvement of [Company B].

61 The Wife’s first basis for substantial improvement is her domestic contributions, namely her homemaking and caregiving, her transition from full-time to part-time employment to care for the Child and her bearing of the greater share of household and the Child’s expenses. I do not accept that these contributions amount to a substantial improvement of the [Company B] Shares.

62 The meaning of “substantial improvement” has been laid down by the Court of Appeal in USB v USA [2020] 2 SLR 588 (“USB v USA”) (at [21]–[22]):

63 The inquiry for “substantial improvement” hence requires either (a) an investment of money or money’s worth in the asset, or (b) the application of effort towards the asset. In either case, the contribution must result in an improvement that is measurable in economic terms. I note that the above passage by the Court of Appeal in USB v USA was set out in the context of a pre-marital asset (USB v USA at [19] and [21]). However, as the wording of s 112(10)(a)(ii) governing pre-marital assets is in pari materia with the “substantial improvement” exception applicable to gifts and inheritances (see Wan Lai Cheng v Quek Seow Kee [2012] 4 SLR 405 at [43]–[46]), the same test applies equally in the present context.

64 Inherent in this test set down by the Court of Appeal is the requirement of a direct causal connection between the contribution and the improvement of the asset. This requirement has been consistently articulated in the case law preceding USB v USA (Hoong Khai Soon v Cheng Kwee Eng [1993] 1 SLR(R) 823 (“Hoong Khai Soon”) at [11]; Chen Siew Hwee v Low Kee Guan [2006] 4 SLR(R) 605 at [51]). Although the Court of Appeal in USB v USA did not adopt that precise phrase, it is, to my mind, embedded within the test – that the investment must be “for the improvement of the asset”, and the effort must have “contributed to an improvement in the asset”. A contribution that does not causally connect to the improvement of the asset cannot satisfy either limb.

65 Applying these principles, the Wife’s domestic contributions fail at the outset. Her homemaking, caregiving and bearing of household and the Child’s expenses do not constitute an investment of money or money’s worth in the [Company B] Shares. The Wife’s expenditure was directed towards the upkeep of the marriage, the home and the Child’s needs, not towards [Company B] itself. Her domestic efforts also cannot be characterised as the application of effort having economic value towards [Company B]. It is undisputed that the Wife was not involved in running the company in any capacity. Her contributions, however substantial and commendable as contributions to the marriage, were directed entirely towards the family, not the business.

66 In this regard, courts have consistently rejected the contention that domestic contributions can amount to substantial improvement of a company’s shares, on the basis that such contributions bear no connection to the shares themselves (Chow Hoo Siong v Lee Dawn Audrey [2003] 4 SLR(R) 481 at [13]–[15]; WGE v WGF [2023] SGHCF 26 (“WGE v WGF”) at [41]–[43]; XIB v XIA at [45]–[51]).

67 The Wife’s case does not succeed by framing her argument as one of freeing the Husband to devote his energies to building [Company B]. The Court of Appeal in Hoong Khai Soon did observe, in the course of finding that a wife’s domestic contributions did not substantially improve the disputed business, that the case before it was “not a case where a spouse’s efforts in the home frees the other spouse to devote his or her energies to the running of a business” (Hoong Khai Soon at [15]). But subsequent cases have noted that this observation was made in obiter, and that notwithstanding that observation, the Court of Appeal in Hoong Khai Soon still found that the wife’s domestic contributions of doing the household chores, looking after the husband’s family, and helping out in another business owned by the husband’s father did not substantially improve the business (WGE v WGF at [42]–[43]; XIB v XIA at [38]). I agree, and I add that the Court of Appeal in USB v USA signalled a firmer and more exacting approach to what constitutes substantial improvement of a business asset. It noted that its earlier decision in Koh Kim Lan Angela v Choong Kian Haw [1993] 3 SLR(R) 491, which had construed a wife’s attendance at her husband’s boutique business events as satisfying the substantial improvement requirement, “may no longer hold true”. If even a spouse’s direct participation in business-related activities may no longer suffice, it follows a fortiori that purely domestic contributions would hardly, if ever, establish the direct causal connection that substantial improvement requires. The home and the business are distinct domains. It is difficult to conceive of circumstances in which contributions confined to the domestic sphere could ever be said to have directly improved a business asset and, to my mind, domestic contributions will rarely, if ever, clear that bar.

68 I add that although the Wife made significant contributions to the marriage by taking on the larger share of homemaking and caregiving, working part-time for 13 years and bearing the greater share of the household expenses, home loan and the Child’s expenses, the shouldering of financial and caregiving responsibilities between spouses is an ordinary incident of marriage, and couples divide that burden according to their circumstances. Where one spouse has a more stable income, it may fall to that spouse to carry a greater financial burden, as the Wife did during the years when the Husband was drawing little from [Company B]. A spouse’s decision to step back from full-time work to care for the children is also a sacrifice made for the family. These are simply the vicissitudes of a shared married life. It would, in my judgment, be a mistake to recast the ordinary give-and-take of a marriage as an investment in, or effort directed at, a company owned by one spouse.

69 I therefore find that the Wife’s domestic contributions did not amount to a substantial improvement of the [Company B] Shares.

70 The more difficult question is whether the Wife’s loans to the Husband, and in particular the 2012 Loan, amount to a substantial improvement of the [Company B] Shares. Having considered the parties’ submissions and the evidence, I have come to the conclusion they do not.

71 First, a loan extended towards a business, or extended towards a spouse that is used for the business, does not satisfy either of the two limbs in USB v USA (see above at [62]–[63]). It is neither effort expended towards improving the company’s shares, nor an investment of money or money’s worth in those shares. When a spouse invests in a company, he or she commits funds to the enterprise and shares in its fortunes. A loan, by contrast, is advanced on terms of repayment and, once repaid, leaves no lasting application of value in the asset.

72 Second, and relatedly, a loan extended towards a business is one step removed from the asset in question, which are the company’s shares. A loan is, at its core, nothing more than the provision of money. What the business does with that money is a separate question altogether, and one over which the lending spouse has no control. The money could be wisely deployed to grow the business, or it could be frittered away on expenses that do not yield lasting value. The company could emerge stronger, or it could sink further into debt. The point is that the mere act of lending does not, by itself, move the needle on the value of the shares in any direction. There is no necessary or reliable connection between the extension of a loan and an improvement in the asset. To treat a loan as substantial improvement would be to conflate the act of lending with the outcome of growth, when the two are not the same thing and may not have anything to do with each other.

73 I recognise that the analysis becomes more difficult where the loan did not merely tide the company over a rough patch, but arguably averted something far more serious, such as the collapse of the business altogether. This is precisely the Wife’s case in respect of the 2012 Loan. She argues that it staved off the Husband’s bankruptcy, preserved his ability to remain a director of [Company B] and without it the company could not have continued to operate and flourish as it has. ¹¹¹ The argument, on the face of it, has an intuitive appeal. Even if the loan was not effort expended or an investment in the conventional sense, one might ask: if the asset would not exist at all but for the loan, does that not count for something? In other words, can substantial improvement not be made out on the basis that the asset would otherwise have been lost?

74 I do not think this line of reasoning should be adopted, for it leads down a dangerous path. The moment the court begins to assess substantial improvement by reference to what might have happened had the spouse not acted, it has left the realm of inquiry that USB v USA prescribes and entered the realm of speculation. How would anyone know with confidence what would have transpired had the 2012 Loan not been extended? Could the Husband have found alternative financing? Even if he had been made a bankrupt, would [Company B] necessarily have been affected? These are questions that cannot be answered with any certainty, and any attempt to answer them strays away from the test for substantial improvement laid down by the Court of Appeal in USB v USA to a but-for inquiry. The test asks what the spouse did and whether that act constituted effort or an investment of money or money’s worth directed at the asset itself. A counterfactual inquiry into what might have been lost, in my view, ought not to form part of that analysis.

75 Even if I am wrong on that, the 2012 Loan faces a further and independent difficulty. It was a personal loan extended to the Husband to settle a personal debt. It was not directed at the [Company B] Shares as an asset and had no direct link to those shares. The chain of reasoning the Wife advances is a long one, and one that I cannot accept: that the loan settled the Husband’s personal debt, which prevented his bankruptcy, which preserved his directorship, which allowed him to continue running [Company B], which in turn enabled the company to grow into the successful business it is today. This is not the direct causal link between the contribution and the improvement of the asset that the law requires. The asset in question is the shares, and the Wife’s contribution must be assessed by reference to that asset, not by tracing a winding path of hypothetical consequences that eventually leads back to it.

76 The final point that the Wife makes in supplementary submissions is with reference to XIB v XIA at [46], where Faizal JC made the following observation: ¹¹²

77 From this passage, the Wife argues that by lending the Husband money to pay staff salaries, CPF contributions, and equipment costs, and by providing further loans after the bankruptcy proceedings when the Husband could not access credit facilities, she steered [Company B] through multiple crises and maintained its operations. ¹¹³ It may be tempting, at first blush, to accept this characterisation. If the loans help a company weather periods of financial hardship, one may say the loans “maintained” its operations in some sense.

78 But the Wife’s argument takes Faizal JC’s observations out of context. He was making the point that improvement is assessed by the nature and quality of the spouse’s input, not merely by the outcome, so that sustained and skilful contributions to a business may count even where market forces cause the company’s value to fall. The examples Faizal JC gave of steering a company through a crisis, maintaining its operations, and preserving key relationships are all instances of “sustained and skilful contributions” that fall under the second limb of USB v USA, namely effort expended towards the business. He was speaking of a spouse who rolls up her sleeves and embeds herself into the work of the business, who brings her judgment, her effort, and her skill to bear on the company’s affairs and who by doing so leaves a meaningful and lasting mark on the enterprise. In my view, extending a loan is none of those things, even if the loan helped tide the company through financial hardship.

79 For these reasons, I conclude that the [Company B] Shares were not substantially improved by the Wife. The shares, having been established as a gift and not transformed into matrimonial assets, fall outside the matrimonial pool. It follows that no question of valuing the shares arises.

80 However, I note that the Wife’s contributions laid down above fall to be considered as part of the Wife’s indirect contributions to the marriage and taken into account at the division stage (USB v USA at [23]; XIB v XIA at [43]). The Husband also accepts that this approach may be taken. ¹¹⁴

81 The Wife seeks to add back into the matrimonial pool three sums: the Husband’s legal fees, the rental payments and the payments to the Husband’s Alleged Partner. I address each in turn.

82 The Wife seeks to add back the Husband’s legal fees of S$29,300.36. ¹¹⁵ The Husband accepts that these should be added back, but says the rule must apply equally, such that the Wife’s own legal fees of S$20,207.92 must be added back as well. ¹¹⁶

83 It is settled law that the legal costs of matrimonial proceedings are not to be borne by the pool. A party must discharge such costs from his or her own share of the matrimonial assets after division, and not from the common pool (UZN v UZM [2021] 1 SLR 426 (“UZM”) at [45], citing UFU (M.W.) v UFV [2017] SGHCF 23 at [105]). As Lai Siu Chiu J observed in AQT v AQU [2011] SGHC 138 at [37], it would be an “unwise precedent” to allow parties to deduct their legal costs from the pool, for it would render “largely nugatory” any costs order the court might make. The rule applies to both parties alike, there is “no justification for treating the Husband’s legal costs any differently from the Wife’s” (UZM at [45]).

84 It follows that both parties’ legal fees fall to be added back. The Wife resists this in respect of her own fees. She says in her supplementary submissions that her fees were paid after the interim judgment date on 18 July 2024 from her UOB Current One Account No -981-1. Since the parties’ position is that only fees paid before the interim judgment are to be added back, her fees should not be so added. ¹¹⁷ Her concern is one of double counting, and ordinarily it would be well founded. If an account is brought into the pool at its IJ date value, a fee later paid from that account is already reflected in the pooled figure, and to add it back would count it twice.

85 However, this concern does not arise on the facts. The parties agreed the value of the UOB Current One Account No -981-1 to be at S$125,868.15 (see above at [20]), which, based on the Wife’s own bank statement, is the balance as at 31 July 2024, and not the balance as at the IJ date. ¹¹⁸ The pooled figure for that account is therefore already net of the legal fees which the Wife paid after the IJ date. Adding those fees back would restore the account to the value it would have held had the fees not been funded from matrimonial moneys. Notwithstanding the parties’ general agreement that bank accounts be valued as at the IJ date, I see no reason to disturb the value of the UOB Current One Account No -981-1 given that parties have agreed on it, save for adding back both parties’ legal fees to the pool.

86 Accordingly, both parties’ legal fees are added back to the pool: the Husband’s S$29,300.36 and the Wife’s S$20,207.92.

87 The Wife seeks to add back S$180,994, being the rent the Husband paid on the Skyline Apartment from 2 December 2020 to 1 July 2024 (ie, before the IJ date), drawn from his DBS Account No 503-7. Her case is that she was unaware the Husband had been renting the apartment since 2020. ¹¹⁹ He disclosed it only in 2022, explaining that he had rented it “just in case”, which she found illogical given that the parties were then living together in the Matrimonial Home (as the Husband only left the Matrimonial Home in late 2023). ¹²⁰ Additionally, she contends that the rented apartment was used for the Husband’s relationship with his Alleged Partner. ¹²¹

88 The Husband resists this on two grounds. First, the rent ought not to be added back because it was not incurred when divorce was imminent. ¹²² He began renting the apartment in November 2020, more than three years before the Wife commenced divorce proceedings in 2024. In his telling, he rented it to have his own space and sanctuary from the parties’ marital difficulties. ¹²³ Second, the rent was not a wrongful dissipation, that is, assets stashed or spirited away to conceal them or put them beyond the other spouse’s reach. ¹²⁴ The Husband disclosed the tenancy to the Wife in November 2022 and produced the tenancy agreements. ¹²⁵ He denies that the apartment was used for any relationship with his Alleged Partner. ¹²⁶

89 I begin with the guidance of the Court of Appeal in TNL v TNK [2017] 1 SLR 609 (“TNL v TNK”). In TNL v TNK, the Court of Appeal set out when the value of an asset expended by one spouse may be returned to the matrimonial pool (at [24]) (“TNL dicta”):

90 In UZN v UZM [2021] 1 SLR 426 (“UZN v UZM”), the Court of Appeal clarified that adding the sums back into the pool of matrimonial assets under the TNL dicta does not depend on any finding of concealment or wrongdoing. Rather, it rests on the fact that the other spouse did not consent to the expenditure (UZN v UZM at [64]–[65]). A dissipation falling within the TNL dicta may be entirely innocent and fully disclosed. It is to be distinguished from a wrongful dissipation which is a disposition made to place assets beyond the other spouse’s reach (UZN v UZM at [63], [65]). The Court of Appeal also confirmed that the TNL dicta is directed at expenditure once divorce is imminent or after interim judgment, and spending before that is treated differently, going, if anywhere, to the parties’ contributions rather than to the size of the pool (UZN v UZM at [66]–[67]).

91 The basis on which the Wife seeks to add the rental back is not clear from her submissions, as she does not say whether she relies on the TNL dicta, on wrongful dissipation, or on some other footing. In any event, wrongful dissipation is not made out. It requires an intention to place assets beyond the other spouse’s reach (UZN v UZM at [66]), for example, purchasing a property for a third party with whom one is having an adulterous affair, which may be viewed as a wrongful dissipation carried out with the intention of depleting the pool (UZN v UZM at [68]). There is no evidence of any such intention here. The Wife says the Husband used the apartment for his relationship with his Alleged Partner, but the Husband denies any such use, and his evidence is that he rented it to have his “own space and sanctuary away from the marital problems”. ¹²⁷ On the Wife’s own evidence, he also disclosed the tenancy to the Wife in November 2022. ¹²⁸ On the evidence, I am not persuaded that the Husband rented the apartment with the intention of depleting the pool or putting matrimonial moneys beyond the Wife’s reach.

92 I turn to analyse whether the Wife’s claim succeeds under the TNL dicta. To my mind, whether the TNL dicta applies turns on when divorce became imminent, measured against when the Husband incurred the rent. From the tenancy agreements, it is clear that the Husband began renting the apartment from 1 November 2020, at S$3,600 per month for the first two years and S$4,400 per month from 1 November 2022. ¹²⁹ According to the Wife, the Husband told her in November 2022 that he wanted a divorce, that he had consulted a lawyer, and that he had been renting the apartment since 2020 and had recently renewed the lease. ¹³⁰ He raised divorce repeatedly thereafter, and on 9 December 2023 left the matrimonial home and did not return. ¹³¹ The Husband’s own case is that the marriage had been an empty shell since 2010, though he chose to preserve it for the Child’s sake. ¹³² Although the Wife only commenced divorce proceedings on 18 January 2024, and interim judgment was granted on 8 July 2024, the question is whether divorce can be said to have become imminent before those dates.

93 In my judgment, divorce became imminent in November 2022. It was then that the Husband made his intention to divorce known to the Wife, told her he had consulted a lawyer, and confronted her with the tenancy he had until then kept from her. Before that point, the parties were still living together in the matrimonial home, and the Wife was unaware of the rental. Expenditure during that period was expenditure during a subsisting marriage, and is not caught by the TNL dicta (UZN v UZM at [66]–[67]). However, after November 2022 when the divorce became imminent, the rent paid from then until the IJ date was a substantial sum expended without the Wife’s consent, in which she had at least a putative interest and, to my mind, it falls within the requirements of the TNL dicta.

94 From the Husband’s bank statements, the Wife computes the total rent from December 2020 to 1 July 2024 at S$180,994. ¹³³ Only the sums from the period when divorce was imminent to the IJ date are to be added back. According to the tenancy agreement, the rent from November 2022 was S$4,400 per month, over the 20 months from 1 November 2022 to the IJ date of 8 July 2024. This amounts to S$88,000. ¹³⁴ To this I add the security deposit of S$5,200 paid on the renewal of the lease in November 2022. ¹³⁵ Although a deposit is in principle refundable, this sum was paid from matrimonial moneys and remains held by the landlord under a tenancy that the Husband continues to maintain to date. It has thus been removed from the pool, without the Wife’s consent. I therefore add back a total of S$93,200 in respect of the rental of the apartment.

95 The Wife claims that between 2020 and the IJ date, the Husband had transferred a total of S$128,116 to his Alleged Partner. ¹³⁶ She argues that the Husband has not given any adequate explanation for these transfers. ¹³⁷

96 The Husband denies any dissipation. His case is that his Alleged Partner lent him money for [Company B]’s cashflow and expenses, and that his transfers to her were repayments of those loans. ¹³⁸ He says the Wife’s tabulation is one-sided, as she has listed only his transfers to the Alleged Partner while omitting the Alleged Partner’s transfers to him. When both directions are tabulated, he submits, each payment to the Alleged Partner can generally be matched to an earlier advance from her, and from 2020 to 2023 the flows in each direction were almost equal. ¹³⁹ Hence, the payments were loan repayments, not dissipation, and should not be added back. ¹⁴⁰

97 At the hearing, I directed counsel to file written submissions identifying where the discrepancy, if any, lay. ¹⁴¹ Pursuant to that direction, the Wife made the following points in supplementary submissions. First, she does not accept two cash deposits into the Husband’s account of S$1,250 and S$20,000, which the Husband says came from the Alleged Partner. ¹⁴² She says there is no evidence that they did. ¹⁴³ She calculates that, once those two deposits are removed, the Alleged Partner transferred S$114,306.13 to the Husband, against S$128,116 transferred by the Husband to her, so that the Husband paid the Alleged Partner some S$13,809.87 more than he received, which she says is inconsistent with the transfers being loan repayments. ¹⁴⁴ Second, she submits that the Husband has not shown that the moneys the Alleged Partner paid into his account were loans. ¹⁴⁵ There is no indication of who transferred first, no record of the purported loans or of any outstanding balance, and no running account. ¹⁴⁶ Third, she says that if the Alleged Partner were truly lending for [Company B]’s expenses, she would have paid the company directly rather than routing the money through the Husband. ¹⁴⁷ On those grounds, the Wife submits that the full S$128,116 should be added back to the pool. ¹⁴⁸

98 I decline to add any such sums back into the matrimonial pool. First, it is not even clear on what basis the Wife seeks to add these moneys back. Counsel for the Wife, Ms Geralyn Danker, did not advance any argument under the TNL dicta, wrongful dissipation, or any other ground. Second, and in any event, I am satisfied on the Husband’s tabulation, drawn from the underlying bank statements, that the transfers between him and the Alleged Partner substantially even out, consistent with a running account of loans and repayments rather than a one-way depletion of matrimonial moneys. ¹⁴⁹ As to the two disputed cash deposits, the Wife says there is no evidence they came from the Alleged Partner, but she offers no positive evidence as to any other source, nor point to anything in the records inconsistent with the Husband’s account. Regarding the absence of any documentary record of formal loans, and the fact that the Alleged Partner transferred moneys to the Husband directly rather than to [Company B] despite his evidence that the loans were for the company, both of these features are consistent with how closely the Husband’s personal finances were intertwined with [Company B]’s. On the evidence, I accept the Husband’s account that the transfers were repayments of loans from the Alleged Partner, and I do not add them back to the matrimonial pool.

99 Taking into account the assets addressed above, together with the Husband’s undisputed assets, the following assets in the Husband’s sole name are added to the matrimonial pool:

100 I note that in supplementary submissions, the Wife sought, for the first time, to add the Husband’s club membership at a marina club at a value of S$12,000. ¹⁵⁰ The item does not appear in the Joint Summary, and it was not the subject of the parties’ affidavit evidence. The Husband has had no proper opportunity to respond, thus I decline to include it.

101 It follows that the matrimonial pool comprises:

(a) Joint assets (see [4] above): S$1,477,552.21

(b) Assets in the Wife’s name (see [20] above): S$969,291.41

(c) Assets in the Husband’s name (see [99] above): S$428,802.88

102 The total value of the matrimonial pool is accordingly S$2,875,646.50.

103 Where both spouses have earned income during the marriage, the applicable framework is the structured approach set out in ANJ v ANK [2015] 4 SLR 1043 (“ANJ v ANK”). The broad-brush approach is reserved for long single-income marriages (TNL v TNK at [46]). Under the structured approach, the court first ascribes a ratio representing the parties’ direct contributions, having regard to their financial contributions towards the acquisition or improvement of the matrimonial assets. Secondly, the court ascribes a ratio representing their indirect contributions, financial and non-financial, to the welfare of the family. Third, the court derives each party’s average percentage contribution from those two ratios, which forms the basis for division, subject to any adjustment for the other factors in s 112(2) of the Women’s Charter (ANJ v ANK at [22]).

104 Both parties worked throughout the marriage. This was therefore a dual-income marriage, for which the appropriate framework is the structured approach in ANJ v ANK. Both parties adopted that approach in their submissions, ¹⁵¹ and I agree that it applies.

105 I begin with the parties’ direct contributions. Other than the joint asset of the Matrimonial Home, the parties accept that each contributed fully to the assets held in his or her own name. ¹⁵² The [Company B] Shares are the one exception but, as I have found, they do not form part of the pool. It is therefore only the parties’ respective contributions to the Matrimonial Home that are in dispute.

106 Both parties accept that the direct contributions to the Matrimonial Home comprise three components: the cash proceeds of sale of the parties’ first home (“First Home”), which were applied towards the purchase of the Matrimonial Home; the parties’ respective CPF contributions to the Matrimonial Home; and their cash payments towards the mortgage. ¹⁵³ The Wife additionally relies on three loans from her parents which she says funded the purchase of the First Home and the Matrimonial Home. She claims that these loans ought to be credited to her as direct contributions. ¹⁵⁴ For the reasons given below, I decline to take the loans into account.

107 The parties received cash proceeds of S$420,796.72 from the sale of the First Home. ¹⁵⁵ It is undisputed that the entirety of these sale proceeds were applied towards the purchase of the Matrimonial Home. Both parties also agree that the sale proceeds of the First Home should be apportioned according to their respective direct contributions to that property, and that the apportioned amounts should then be taken into account in calculating their direct contributions to the Matrimonial Home. This approach has been adopted in other cases (see for eg, Goh Cheok Yean v Lum Sai Gek [2014] SGHC 91 at [32]) and I will apply the same approach here. The only dispute is how much each party contributed to the First Home.

108 I turn first to the Wife’s claim that her parents provided a loan towards the downpayment of the First Home. The Wife says her parents extended a cash loan of S$100,000 towards the downpayment of the First Home, and that this loan remains unpaid. ¹⁵⁶ She says it is “likely that [she] would have to repay her parents”. ¹⁵⁷ On that basis, she seeks to have the S$100,000 loan attributed to her as a direct contribution to the First Home. ¹⁵⁸ The Husband’s position is that this S$100,000 from her parents was not a loan, but a gift to them as a couple. ¹⁵⁹

109 I am unable to conclude, on the evidence before me, that the S$100,000 from the Wife’s parents was a loan. The Wife has not produced any contemporaneous evidence to substantiate her claim. Even if such a loan exists, it would not on these facts qualify as a direct contribution. The law does not categorically exclude unrepaid loans from counting as direct contributions. Whether they are excluded depends on the facts, and in particular on whether the circumstances establish a clear obligation on the part of the spouse claiming the contribution to repay the loan and whether repayment has in fact been made towards it. In VZJ v VZK [2024] SGHCF 16, Mavis Chionh Sze Chyi J attributed both the repayments already made by the wife to the husband’s parents and the outstanding balance to the respective parties as their direct contributions (at [45]). The wife’s partial repayments arguably lent credence to the conclusion that the loan was genuinely repayable and that the husband would likewise be required to repay his share in due course. By contrast, in XCZ v XDA [2025] SGHCF 38, Choo J declined to attribute a loan from the husband’s mother to either party as a direct contribution. Neither spouse had made any repayment towards the loan, which was to be repaid only upon the sale of the matrimonial home out of the sale proceeds. The loan was therefore treated as a liability to be deducted from the sale proceeds, rather than as a direct contribution by either party (at [27]).

110 On the present facts, neither party has made any repayment towards the loan and there is nothing to suggest that either party will eventually have to do so. The Wife’s own account is that the loan was extended to the parties in 2001, more than 20 years ago. Yet it is only now, in the context of these proceedings, that she asserts that the loan remains outstanding and that she “would likely have to repay” her parents. This assertion is unsupported by any evidence and I do not accept it. The Wife has also not made any repayment towards the loan. She points only to a prospective liability that may or may not crystallise. I therefore decline to attribute the S$100,000 to her as a direct contribution to the First Home.

111 I turn next to the parties’ respective contributions to the First Home. It is not in dispute that the Wife contributed S$270,809.46 and the Husband S$128,573.15 by way of CPF. ¹⁶⁰ The Husband alleges that the parties’ practice has always been to split the downpayment of the home and the monthly loan instalments as equally as possible. ¹⁶¹ His evidence is that for the First Home, although his CPF contributions were lower than the Wife, his cash contributions were higher, such that the parties’ overall contributions were equal. ¹⁶² In response, the Wife produced bank statements relating to the mortgage for some months, showing that the monthly repayments were met entirely through CPF contributions. ¹⁶³

112 I reject the Husband’s claim that he had made cash contributions to the First Home such that the parties’ contributed equally overall. This was nothing more than a bare assertion, with no evidence that he had even made any cash contributions at all. In light of the bank statements for the mortgage produced by the Wife for certain months showing that the monthly mortgage was met entirely through CPF, and in the absence of any evidence by the Husband, I find it more likely than not that the mortgage was serviced solely through CPF contributions throughout. I accept the Wife’s evidence that no cash contributions were made, and that she contributed more to the First Home than the Husband by virtue of her higher CPF contributions.

113 I therefore apportion the First Home proceeds of S$420,796.72 in the ratio of the parties’ documented CPF contributions. The Wife’s CPF contribution of S$270,809.46 and the Husband’s CPF contribution of S$128,573.15 total S$399,382.61, giving rise to a ratio of 67.81% to the Wife and 32.19% to the Husband. Applied to the proceeds, the Wife’s share is S$285,342.26 and the Husband’s is S$135,454.46. To be clear, I do not take the alleged S$100,000 loan from the Wife’s parents into account.

114 The Wife’s CPF contribution of S$553,976.51 as at October 2024 to the Matrimonial Home is documented and undisputed by the parties. ¹⁶⁴ As for the Husband’s CPF contribution, the Wife claims that it is S$277,189.89, relying on a screenshot from cpf.gov.sg as at 17 November 2024. ¹⁶⁵ The Husband puts forward a marginally higher figure of S$279,491.64 for his CPF contribution, ¹⁶⁶ relying on yearly CPF statements from 2017 to 2024. ¹⁶⁷ The difference between the two figures is negligible in the grand scheme of things, and I adopt the midpoint of both figures, which is S$278,340.77, as the Husband’s CPF contribution.

115  On cash payments towards the mortgage, the parties’ figures are far apart. The Wife says she contributed S$228,452.69 and the Husband S$100,359.35. ¹⁶⁸ The Husband’s position is that the Wife contributed S$187,232.43 while he contributed S$336,166.44. ¹⁶⁹

116 I set out the background to the housing loans, which is undisputed by the parties. When the parties purchased the Matrimonial Home in August 2016, they took out a home loan from Maybank (“Maybank HL”) and, as a condition of that loan, opened a joint account for the purposes of servicing it. ¹⁷⁰ From around July 2022, the Maybank HL was refinanced with UOB (“UOB HL”). ¹⁷¹ The UOB HL instalments were linked to the Wife’s UOB account, from which monthly payments were deducted by GIRO. ¹⁷²

117 I first address the Wife’s claim that her mother extended a loan of S$100,000 which was used to service the Maybank HL. The Wife says that when the parties opened the joint Maybank account to service the Maybank HL, a minimum deposit of S$100,000 was required. ¹⁷³ She says that her mother loaned that sum to them, and the deposit was subsequently drawn down to meet the monthly mortgage payments, from August 2016 to December 2018. ¹⁷⁴ On her case, she has to repay this sum and thus she seeks for it to be added as her direct contribution.

118 In support of her claim, the Wife adduces two pieces of evidence. The first is a Maybank bank statement for February 2017 reflecting an opening balance of S$97,784.78 as at 1 January 2017. ¹⁷⁵ She explains that the S$100,000 loan from her mother had already been partially drawn down in the months between the purchase of the Matrimonial Home in August 2016 and the date of the statement. ¹⁷⁶ The second is a photograph of a page in a cheque book dated 30 July 2016 for S$100,000, bearing a description that includes the Wife’s initials and the word “loan”. ¹⁷⁷

119 The Husband denies the existence of this loan. ¹⁷⁸ In his supplementary submissions, the Husband exhibits a table setting out his monthly CPF and cash contributions to both housing loans (“the Annex B Table”). ¹⁷⁹ For the period from August 2016 to December 2018, the Annex B Table records that he “passed cash to [the Wife] for his share of the monthly mortgage”. ¹⁸⁰

120 On the evidence, I am satisfied that there was a deposit of S$100,000 from Wife’s mother in the joint account, that was used to pay the Maybank HL from August 2016 to December 2018. Ordinarily, a bank statement showing an opening balance, together with a photograph of a cheque book, would be inconclusive. Here, however, two further matters convince me that this deposit existed. First, although the Husband denies that the loan exists, he does not himself lay claim to the S$100,000 in the account, nor does he offer any alternative account of whose money it was. Second, his own evidence on the servicing of the loan does not withstand scrutiny.

121 It is of particular significance to me that in the Annex B Table, there is completely no reference to documentary evidence of any such cash payment during that period of August 2016 to December 2018. The only exception is June 2018, when the bank statement records a transfer of S$10,000 from the Husband to the Wife’s OCBC 360 Account. I do not accept this transfer as his cash payment towards the Maybank HL. There is nothing to show that the S$10,000, paid into the Wife’s personal OCBC 360 Account, was applied to the Maybank HL. The pattern of payment in the following months also tells against the Husband’s account. It shows that the parties’ practice was for the Wife to pay the Husband her share, and for the Husband to then transfer the full monthly instalment into the parties’ joint Maybank account. It is, to my mind, unlikely that the Husband would instead pay a lump sum into the Wife’s personal account to service the Maybank HL in June 2018, when the loan was serviced from the parties’ joint account. Further, on his own case in the Annex B Table, he was making regular monthly cash payments in the months before and after June 2018. There would be no reason for him to suddenly pay a large sum of S$10,000 for the mortgage on June 2018. As such, I am of the view that the S$10,000 transfer to his Wife was not a payment towards the Maybank home loan, and I am satisfied that the Maybank HL was serviced during the period from August 2016 to December 2018 using the S$100,000 deposit provided by the Wife’s mother.

122 However, I reject the contention that this S$100,000 should be attributed as either party’s direct contribution to the Matrimonial Home. The same difficulty that arises in respect of the First Home loan applies here (see above at [109]–[110]). The alleged loan was extended more than ten years ago, yet neither party has made any repayment towards it, and the obligation to repay remains entirely unclear. I am not persuaded that any live repayable obligation exists and the Wife’s claim that this sum should be attributed as her direct contribution does not succeed.

123 I next address the parties’ cash contributions towards both mortgages. Their evidence on this issue is thoroughly unsatisfactory. Neither party produced a reliable account of their cash contributions. For ease of analysis, I consider the cash contributions in two periods. First, the parties’ cash payments towards the Maybank HL from January 2019 to June 2022, the month before the loan was refinanced. This follows my finding that the loan was serviced from the S$100,000 deposit until about December 2018. Second, their cash payments towards the UOB HL from July 2022 to November 2024, being the date that parties have agreed is the operative date for the CPF contributions, which I adopt here for consistency.

124 I find several difficulties with both the Husband’s account in the Annex B Table, and the Wife’s account in her Excel spreadsheet recording her monthly cash and CPF contributions (“Excel Sheet”). ¹⁸¹

125 For the period from January 2019 to September 2019, neither account is supported by documentary evidence. The Husband records his monthly cash payments as ranging from about S$1,900 to S$4,500. Taken with the S$1,700 CPF contribution he says he paid each month, this means that for some months he claims to have paid around S$6,200 of a monthly instalment of roughly S$7,300 to S$7,600. He produces no evidence in support of his claims, saying that in some months he passed cash directly to the Wife for his share, and in other months he paid into the parties’ joint Maybank account. I find the precision of his figures for cash payments implausible. The Husband claims to have passed the Wife cash of exactly S$1,966.36 in February and March 2019, and S$1,991.37 in June 2019. It is difficult to see how cash sums carrying odd cents would have been handed over to the Wife in that way.

126 The Wife’s account for the same period is also unsatisfactory. In the Excel Sheet, she records consistent cash payments by her of about S$1,500 to S$2,800 and CPF payments of about S$2,100 each month. This means that on her account, she paid about S$3,600 to S$4,900 each month towards the monthly instalment. This cannot be reconciled with the Husband’s account. Her figures are also unsupported by any document and amount to bare assertions.

127 I find that, for this period, both parties have reconstructed figures to suit their respective positions in the absence of any underlying record, and that neither account can be relied on.

128 For the period from October 2019 to June 2022, there is more documentary evidence. Both parties accept, and the documents confirm, that their general practice was for the Wife to transfer her half share to the Husband each month, and for the Husband then to pay the full instalment into the joint account to service the Maybank HL. This practice is borne out by the WhatsApp exchanges adduced by the Husband. ¹⁸² One exchange dated 10 April 2019 shows each party contributing S$5,000, and another dated 31 August 2021 shows each party contributing S$2,500. These exchanges establish a consistent practice of broadly equal cash contributions towards the Maybank HL. Significantly, the WhatsApp exchange of 10 April 2019 indicates that the practice of equal contributions was already in place for the period that parties have reconstructed figures (see above at [127]).

129 On the limited evidence available, I find that the parties contributed cash to the Maybank HL in broadly equal shares across the period from January 2019 to June 2022. In the absence of documentary evidence for the earlier months, and given that the WhatsApp exchanges establish a practice of equal contributions, there is no evidence to suggest that the payments for these months would have been materially different. What remains is to identify a total sum of cash contributions for this period to be divided equally between them.

130 By a letter dated 16 September 2026 (“16 September Letter”), I directed the parties to agree, so far as possible, the total cash paid towards the Maybank HL from January 2019 to June 2022. The Wife provides a figure of S$162,989.29. The Husband’s position is that he is unable to provide a figure because the Maybank statements do not distinguish cash from CPF payments, recording only “principal payment” and “interest payment”. He claims that the Wife’s figure is overstated because it includes CPF contributions.

131 The Husband has not provided his own figure for the cash contributions towards the Maybank HL, and I am not satisfied that he has shown that the Wife’s figure of S$162,989.29 is inflated by the inclusion of CPF. The Husband’s argument appears to be premised on the assumption that the Wife derived her figures from the mortgage payment documents, which would capture the total monthly mortgage payment inclusive of both cash and CPF components. However, the Wife’s table indicates that she relied on “bank statement cash deduction letters”, which would only reflect actual cash deductions from her bank account and would not capture CPF payments, since CPF payments are deducted from a CPF account and not a bank account. This is borne out by the fact that the Wife’s figures for each month are consistently lower than the total monthly mortgage payments. Had she inadvertently included CPF, her figures would be expected to be closer to or equal to the full monthly mortgage payment. The Husband’s explanation therefore does not hold water. I accordingly accept the Wife’s figure of S$162,989.29 as the total cash contributions towards the Maybank HL and attribute S$81,494.65 to each party. Given the absence of any alternative figure from the Husband and my finding that the Wife’s figure has not been proven to be inflated, I take the view that this is the appropriate approach on the evidence before me.

132 It is undisputed that after the Maybank HL was refinanced, the UOB HL was taken out in the Wife’s name, and the monthly instalments were paid by GIRO from her UOB account. For this period, the Husband’s cash contributions are grounded in documentary evidence. In the Annex B Table, he cites bank statements reflecting the sums he transferred to the Wife each month from July 2022 to November 2024, being his reimbursement of his share of the instalments. These records show that he consistently paid half, and in some months close to the whole, of the monthly cash contributions.

133 The Wife’s Excel Sheet largely corresponds to the Husband’s account. Indeed, her own figures do not support her case that she was regularly covering the Husband’s shortfall and bearing the larger share of the cash contributions towards the UOB HL. ¹⁸³

134  There are only two points of discrepancy between the parties’ accounts. First, for October and November 2022, the Wife records the monthly cash instalment as S$1,318.13, but the Husband records it as S$3,586.26. Second, for January and February 2023, the parties agree the monthly cash instalment was S$1,318.13, but the Wife records paying only S$100.13 and the Husband records that he did not contribute for those months.

135 Given these points of discrepancy, I directed the parties in the 16 September Letter to provide a figure for the total cash paid towards the UOB HL from July 2022 to November 2024. The Wife and Husband provided figures of S$50,280.82 and S$54,817.08 respectively. As the two figures are close, I adopt the midpoint of S$52,548.95 as the total cash contribution towards the loan for this period. Based on the documentary evidence of the Husband’s transfers of his share of the instalments to the Wife’s OCBC account, I add up the sums for those months supported by the underlying documents. These amount to S$40,816.48 and represent the Husband’s cash contributions towards the UOB HL. Deducting this sum from the total cash contribution of S$52,548.95 leaves S$11,732.47, which I attribute to the Wife. Therefore, for the period from July 2022 to November 2024, I find that the Husband made cash contributions towards the UOB HL of S$40,816.48 and the balance S$11,732.47 was paid by the Wife.

136 On this basis, as at November 2024, the Husband’s cash contribution to the Matrimonial Home is approximately S$122,311.13, comprising S$81,494.65 towards the Maybank HL and S$40,816.48 towards the UOB HL. The Wife’s cash contribution is approximately S$93,227.12, comprising S$81,494.65 towards the Maybank HL and S$11,732.47 towards the UOB HL. These figures are not precise, but they are the best approximation the evidence permits. Where the evidence does not permit confident findings, the court takes a “rough and ready” approach and does the best it can with what is before it (ANJ v ANK at [23]).

137 Finally, I address the S$250,000 loan from the Wife’s parents. The Wife says this was extended towards the downpayment of the Matrimonial Home and has since been fully repaid, ¹⁸⁴ and that S$125,000 should accordingly be added to each party’s direct contribution figures. ¹⁸⁵ The Husband says it was a bridging loan from the Wife’s parents, taken out because the parties had purchased the Matrimonial Home before selling the First Home, and that it was repaid in full once the First Home was sold. ¹⁸⁶ Given that parties agree that this loan existed and has been repaid in full, I accept their evidence on this and I accordingly add S$125,000 to each party’s direct contributions to the Matrimonial Home.

138 In light of the above, the parties’ direct contributions to the Matrimonial Home are as follows:

139 The parties’ direct contributions are as follows:

140 The Wife submits that the ratio for indirect contributions should be 75:25 in her favour, ¹⁸⁷ while the Husband submits for an equal split of 50:50. ¹⁸⁸

141 The Wife’s case is that she made far greater contributions across the board. She gave up full-time work for some 13 years after the Child’s birth, estimating a loss of income of around S$800,000, ¹⁸⁹ and during that time served as the primary caregiver, ferrying the Child to school and activities, managing the Child’s scoliosis treatment, and liaising with teachers and medical professionals. ¹⁹⁰ She also says she bore the overwhelming majority of household and child-related expenses, including school fees, tuition fees, medical bills, and insurance premiums, and provided the Husband with financial and personal support during difficult periods at [Company B]. ¹⁹¹ She further asks the court to take into account the Husband’s conduct, including his concealment of a rental property and the circumstances surrounding his announcement of the divorce. ¹⁹²

142 The Husband, for his part, says both parties worked and contributed to the household and to the Child’s upbringing. ¹⁹³ He contends that the parties divided household expenses between themselves, that he took over the Child’s expenses when she entered junior college and university and that he was heavily involved in the Child’s life. ¹⁹⁴

143 I address the parties’ indirect financial contributions and indirect non-financial contributions in turn.

144 It is clear to me that the Wife bore the greater share of the indirect financial contributions. For much of the marriage, she kept the household running and the Child provided for. The Husband did not seriously challenge her evidence that she met the majority of household and child-related expenses, including school fees, tuition and enrichment fees and the Child’s insurance and education policies. The Husband’s response in his affidavit is only that the parties paid equally for the cost of the Child’s scoliosis treatment, and that while the Wife paid for the Child’s expenses and groceries, he covered the MCST fees, utilities, Singtel and internet bills, and car expenses. ¹⁹⁵ The Wife disputes this, saying she paid a large proportion of the conservancy and maintenance costs for both the First Home and the Matrimonial Home. ¹⁹⁶ In support of his position, the Husband adduced records of recent Singtel and MCST payments. However, the Singtel records cover only July and August 2025, and the MCST records show two payments on 30 April and 6 August without indicating which year they were made. ¹⁹⁷ These isolated payments, in my view, fall short of establishing that he had consistently paid these bills throughout the marriage.

145 I also take into account the undisputed fact that the Husband only began drawing a salary from [Company B] in June 2021, receiving only ad hoc director’s fees prior to that point. It is difficult to see how he could have regularly met these expenses before that point. Even accepting that he paid these bills on most occasions, the evidence as a whole clearly shows that the Wife contributed more to the household finances overall. She was the one who consistently and over many years met the bulk of the household and child-related expenses, while the Husband’s contributions, even on his own account, were limited to a handful of recurring bills.

146 Beyond the home, the Wife also lent the Husband moneys when [Company B] faced cashflow difficulties, and came to his aid in 2012 when bankruptcy proceedings were brought against him, lending him the sum he needed to discharge the debt (see above at [57]–[58]). Although I did not find these acts to have substantially improved the [Company B] Shares, they ought to be taken into account in her favour as indirect financial contributions made to the family.

147 I accept that from 2019, when the Child entered junior college and later university, the Husband took over her expenses and allowance, and he met the maintenance charges on the home and the costs of the family car. But plainly, his indirect financial contributions were the lesser of the two and came after the Wife had already carried the greater burden through the years.

148 The Wife’s non-financial contributions were also greater. In 2004, she gave up her full-time job and moved to part-time work. She remained in part-time work for 13 years to raise the Child, giving up the career and earnings she might otherwise have had. I accept her evidence that during that time, she was the one ferrying the Child to school and activities and keeping in touch with her teachers. When the Child’s scoliosis diagnosis came, she took charge of the treatment and arranged for care overseas.

149 While the Husband says that he took the Child to school daily for many years, attended parent-teacher meetings, and was present at her school and church events, the Wife’s evidence, which the Husband does not seriously challenge, is that as the years went on, he became less involved with the family, was often away from home and did not join them on their trips overseas.

150 Looking at the evidence before me as a whole, I am of the view that the Wife made more indirect contributions to the family. She gave up her career, raised the Child through her formative years, bore the greater share of her expenses, and helped the Husband financially when his business was struggling. These were sustained contributions over the course of a long marriage and they warrant a ratio that meaningfully reflects the weight of the Wife’s contributions to the family.

151 Both counsel tendered cases in support of their respective positions on the appropriate ratio for indirect contributions. In particular, Mr Loo tendered a table of cases at the hearing to make the point that a ratio of 75:25 in the Wife’s favour would be “a very skewed and unusual range”, and that a review of the authorities suggests the range typically falls between 50:50 and 60:40, reaching 75:25 only on extreme facts.

152 But the facts of every marriage are necessarily different. Indirect contributions are closely tied to the particular dynamics of each marriage, including how the parties organised their lives, divided their responsibilities and supported one another. The weight to be given to any particular contribution therefore depends on the specific circumstances of the marriage in question. A ratio that is appropriate on one set of facts may be entirely inappropriate on another, and comparing ratios across cases sheds little light on what a fair ratio should be in any given case. It may even risk obscuring rather than illuminating the analysis by suggesting that outcomes in other cases set a benchmark or define a range. The court’s task is ultimately to look at the specific circumstances of the marriage before it and arrive at a ratio that fairly reflects each party’s actual contributions. The question, therefore, is not where this case sits on a spectrum of decided cases, but the appropriate ratio that fairly reflects the parties’ respective contributions on the evidence before me. Suffice it to say that the courts have in appropriate cases attributed indirect contributions as 70:30 or 80:20 in favour of one spouse (see for eg, TQU v TQT [2020] SGCA 8 at [134]; WGE v WGF [2023] SGHCF 26 at [162]).

153 On the facts of this case, I am of the view that a ratio of 70:30 in the Wife’s favour is appropriate. The Wife’s contributions were substantial and sustained across a marriage of more than two decades. She made sacrifices, financial and personal, that enabled the family to function and the Husband to focus on building his business. At the same time, the Husband was not an absent or uninvolved spouse. He contributed to the household, was engaged in the Child’s earlier years, and took on more of her expenses in the later years. A ratio of 70:30, in my view, fairly reflects the indirect contributions of both parties.

154 In written submissions, the Wife devotes several paragraphs to the Husband’s conduct towards the end of the marriage, including his concealment of the rented apartment, his pressure on her to divorce, and the distress she suffered. ¹⁹⁸ But the relief she seeks is not stated and it is not clear to the court what redress she seeks.

155 If she is seeking an adjustment to the indirect contributions ratio on account of the Husband’s conduct, I do not think that is appropriate on the facts. The court may, in dividing matrimonial assets, have regard to a spouse’s conduct, but only where it is both extreme and undisputed, and where it has fundamentally undermined the partnership or harmed the welfare of the other party (Chan Tin Sun v Fong Quay Sim [2015] 2 SLR 195 (“Chan Tin Sun”) at [25] and [27]). This threshold was met in Chan Tin Sun by a wife who “had embarked on a premeditated course of action to inflict harm on the [h]usband by poisoning him over a period of time” (Chan Tin Sun at [54]). The Husband’s conduct here, however hurtful to the Wife, does not approach that very high threshold, and I do not think this is a case for adjusting the ratio on account of his conduct. I therefore do not take into account the Husband’s conduct in assessing the parties’ indirect contributions.

156 The average ratio of the parties’ direct and indirect contributions is therefore:

157 Applying the average ratio to the pool of S$2,875,646.50, the Wife’s share is S$1,941,549.63 and the Husband’s share is S$934,096.87.

158 I turn to the consequential orders. The Wife wishes to retain the Matrimonial Home, in which she resides with the Child. ¹⁹⁹ If each party retains the assets in his or her sole name, the Wife holds assets worth S$969,291.41 and the Husband holds assets worth S$428,802.88. If the Husband’s interest in the Matrimonial Home is transferred to the Wife, she will hold assets worth S$2,446,843.62, being the value of the home (S$1,477,552.21) together with her own assets. This exceeds her entitlement of S$1,941,549.63 by S$505,294, for which she must account to the Husband. There remain two outstanding costs orders in the Wife’s favour, which the Husband has not paid: S$250 for wasted costs for the case conference on 28 April 2025, and S$1,000 for the summonses for discovery and interrogatories heard on 15 July 2025. ²⁰⁰ These total S$1,250. In the interest of a clean break, this sum is set off against the balance payment, reducing it to S$504,044.

159 I make the following orders (see for eg, Chionh J’s consequential orders in XPA v XPB [2025] SGHCF 57 at [132] and YAM v YAN [2026] SGHCF 14 at [152]):

160 I consider it appropriate that neither party should be ordered to pay the other’s costs. Accordingly, each party is to bear his or her own costs.