1 In HC/OA 101/2026 (“OA 101”), the applicant, Goh Seng Heng (“Applicant”), sought the court’s review of several acts, omissions and/or decisions of the Official Assignee, pursuant to ss 30 and 31 of the Bankruptcy Act (Cap 20, 2009 Rev Ed) (“BA”).

2 Having considered the parties’ written and oral submissions, I dismissed OA 101 on 22 July 2026. Six days later, the Applicant appealed. I now elaborate on my oral decision.

3 The Applicant is a medical doctor who founded Aesthetic Medical Partners Pte Ltd (“AMP”). On 20 February 2019, the High Court in HC/S 1311/2025 (“Suit 1311”) found him liable for making fraudulent misrepresentations to representatives of an investment vehicle, Liberty Sky Investments Ltd (“LSI”), which led to LSI purchasing shares in AMP from the Applicant: Liberty Sky Investments Ltd v Goh Seng Heng [2020] 3 SLR 335 (“Liberty Sky Investments (HC)”) at [96]. Damages, to be assessed based on the decline in the value of the AMP shares that LSI beneficially owned, were to be paid by the Applicant to LSI: Liberty Sky Investments (HC) at [106]. In particular, LSI beneficially owned 1,500 shares, and it was awarded “the difference in the purchase price (of $450 per share) and the current value which is to be taken as the date of the assessment of damages”, along with “interest for the difference in the value, at 5.33% per annum from 19 December 2014 … to the date of judgment [ie, 20 February 2019]”: Liberty Sky Investments (HC) at [107]. ¹ LSI was also awarded the loss of stamp duty for the 1,500 shares (with interest) (Liberty Sky Investments (HC) at [109]), as well as any foreign exchange losses suffered for those shares (at [111]). The Applicant’s appeal against this decision was dismissed by the Court of Appeal in a decision dated 10 February 2020: see Liberty Sky Investments Ltd v Aesthetic Medical Partners Pte Ltd [2020] 1 SLR 606 (in particular, at [7]–[10]). ²

4 On 6 March 2020, the Applicant filed a bankruptcy application against himself in HC/B 940/2020. Since this bankruptcy application was made before 30 July 2020, the BA remained applicable: see s 525(1)(b) of the Insolvency, Restructuring and Dissolution Act 2018 (2020 Rev Ed) (“IRDA”). The Applicant was adjudged bankrupt on 19 March 2020, ³ and the Official Assignee was appointed as the trustee of the Applicant’s estate in bankruptcy.

5 Between 18 June 2020 and 8 March 2022, the Official Assignee examined and admitted three proofs of debt, ⁴ one of which was filed by LSI. In particular, on 18 June 2020, LSI’s proof of debt (which was filed on 11 June 2020) was admitted by the Official Assignee at $826,966.99. ⁵ Another proof of debt was filed by LVM Law Chambers LLC (“LVM”), for fees for legal services rendered. The final proof of debt was filed by Wang Xiaopu @ Lucy Wang (“Wang”), who had been awarded damages – to be paid by the Applicant – in a separate suit (HC/S 686/2015, “Suit 686”).

6 Although the Applicant had previously appealed against the High Court’s decision in Suit 686, this was deemed withdrawn when the Applicant failed to provide security for costs. ⁶ The Official Assignee refused to grant sanction to the Applicant to apply for an extension of time to furnish the previously ordered deposit for his appeal, because the Applicant: (a) did not provide a legal opinion on the assessment of the merits of his claim; and (b) did not have a third party place a security for any party-and-party costs that might be ordered against the Official Assignee or the bankruptcy estate. ⁷

7 The Applicant subsequently commenced six applications, seeking permission to commence judicial review proceedings against the Official Assignee. In one of these applications (HC/OA 114/2025), the Applicant sought a quashing order of the Official Assignee’s decision to admit the debts owing to LSI, LVM and Wang. I dismissed this application (along with the five other applications), for the reasons set out in Goh Seng Heng v Official Assignee [2026] 3 SLR 541 (“Goh Seng Heng (JR)”). In so holding, I observed that the Official Assignee’s decision to admit the three proofs of debt “[fell] within the scope of review by the court under s 31 of the BA”, and so the BA provided for a “complete and suitable alternative remedy”, which rendered the application for judicial review inappropriate: Goh Seng Heng (JR) at [63] and [66].

8 In OA 101, the Applicant sought “statutory review and/or directions pursuant to [ss] 30 and 31 of the [BA]” in relation to three categories of decisions by the Official Assignee, ⁸ which the Applicant referred to as Schedules A to C. Schedule A related to the Official Assignee’s refusal to grant sanction to the Applicant to apply for an extension of time to provide a security deposit for his intended appeal against the decision in Suit 686. ⁹ Schedule B related to the Official Assignee’s decision to admit the proofs of debt of Wang and LVM. ¹⁰ Finally, Schedule C related to the Official Assignee’s decision to admit LSI’s proof of debt. ¹¹

9 On 22 July 2026, I dismissed OA 101. In relation to the Applicant’s Schedule A claim, I noted that such dismissal did not preclude the Applicant from satisfying the Official Assignee’s two conditions to grant sanction for him to file an application for an extension of time to appeal against the decision in Suit 686 (see [6] above). As for the Schedules B and C claims, I explained that there was nothing before me that persuaded me that any of the three proofs of debt (in respect of LSI, Wang and LVM) had been admitted incorrectly.

10 The Applicant filed his notice of appeal (“Notice of Appeal”) in relation to OA 101 on 28 July 2026. According to the Applicant’s Notice of Appeal, his appeal was “against the whole of [my] decision” in OA 101. However, the Applicant later clarified in a letter to Court dated 29 July 2026, and in emails to Court dated 31 July 2026 and 4 August 2026, that his appeal was “confined to the dismissal of [the] Schedule C reliefs, together with any consequential costs order attributable to Schedule C”. He also said that his appeal “does not concern Schedule A or Schedule B” of OA 101.

11 I therefore set out my reasons for dismissing the Applicant’s claim for relief in Schedule C of OA 101, beginning first with the applicable legal principles for a court’s review of the Official Assignee’s decision to admit a proof of debt (at [12]–[30]), and then turning to apply those principles to the facts in this case (at [32]–[38]).

12 In his written submissions, ¹² the Applicant cited Yit Chee Wah v Inner Mongolia Huomei-Hongjun Aluminium Electricity Co, Ltd [2025] 1 SLR 1110 (“Inner Mongolia”) for the proposition that he only needed to show a “prima facie reason why the admission or maintenance of a proof is unsafe or improper”.

13 In written and oral submissions, counsel for the Official Assignee submitted that the applicable standard of review by a court of the Official Assignee’s acts, omissions or decisions under s 31 of the BA is the perversity standard. ¹³ Citing Zhang Hong En Jonathan v Private Trustee in Bankruptcy of Zhang Hong’En Jonathan [2021] 4 SLR 139 (“Jonathan Zhang”), it was suggested that the court should ask whether the Official Assignee’s decision was so absurd that no Official Assignee, properly advised or properly instructing himself/herself, could have so acted (ie, the perversity standard). Counsel also distinguished between the standard of review to be applied when a bankrupt seeks review of the Official Assignee’s acts, omissions or decisions under s 31 of the BA (for which the perversity standard should apply), and the standard of review for a creditor’s appeal under r 198 of the Bankruptcy Rules (Cap 20, R 1, 2006 Rev Ed) (“BR”) against the Official Assignee’s decision to reject a proof of debt. It was also submitted that there was no other provision in the BR that provided for a bankrupt to apply for the court’s review of an Official Assignee’s decision on proof of debt.

14 With respect, I disagreed with both parties’ submissions as to the applicable standard of review. In my view, the applicable standard in an application by a bankrupt for the court’s review of the Official Assignee’s decision on a proof of debt under s 31 of the BA is neither a prima facie standard nor the perversity standard. The reviewing court should instead undertake a de novo review of the proof of debt and decide if it should be admitted. This is consistent with my observation in Goh Seng Heng (JR) at [64] that the wording of s 31(1) of the BA suggests that the scope of review “may … extend to reviewing the correctness of decisions taken by the Official Assignee”. For ease of reference, I set out ss 31(1) and 31(2) of the BA:

31.—(1) If a bankrupt or any of his creditors or any other person is dissatisfied by any act, omission or decision of the Official Assignee in relation to the Official Assignee’s administration of the bankrupt’s estate, he may apply to the court to review such act, omission or decision.

[…]

(2) On hearing an application under subsection (1) or (1A), the court may —

(a) confirm, reverse or modify any act or decision of the Official Assignee; or

(b) give such directions to the Official Assignee or make such other order as it may think fit.

15 The Applicant’s submission that he only needed to show a prima facie case that the admission of LSI’s proof was improper was misconceived. This argument rested on a mistaken reliance on Inner Mongolia. In that case, the Court of Appeal set out the two-step test for determining whether the court should expunge a proof of debt, on the application of the liquidator who “thinks that a proof has been improperly admitted”, under r 133(1) of the Insolvency, Restructuring and Dissolution (Corporate Insolvency and Restructuring) Rules 2020 (“CIR Rules”). At the first step, the liquidator must prove, “on a prima facie standard, that the proof of debt sought to be expunged or reduced was improperly admitted”. This decision was premised, inter alia, on the wording of r 133(1) of the CIR Rules: Inner Mongolia at [67]. This case can thus be distinguished on the basis that it concerned a different statute, involving an application by a liquidator in the context of corporate insolvency. No authority or explanation has been provided for transplanting the test set out in Inner Mongolia to the present application by the bankrupt under s 31 of the BA.

16 Turning to the reliance placed on Jonathan Zhang by counsel for the Official Assignee, that case did not concern an application for a court’s review of the Official Assignee’s decision to admit a proof of debt under s 31 of the BA. It instead involved a bankrupt applying under s 43 of the IRDA (which is in pari materia with s 40 of the BA) for a court’s review of the decision of a private trustee in bankruptcy to revoke sanction for the bankrupt to defend a third-party action filed against him (at [1]–[4]). The High Court held that the perversity standard should apply as it struck a balance between the “broad powers” accorded to the court under the BA and the IRDA to “disturb the private trustee’s decision and substitute its own”, and the need to allow the private trustee to do his/her job “without constantly looking over the shoulder to wonder if some complaint will be made” (at [42]–[43]).

17 In so holding, the High Court (at [42]) approved the decision of the English Court of Appeal in Bramston v Haut [2013] 1 WLR 1720 (”Bramston”), in which it was held that the court “is properly reluctant to interfere with the day to day administration by a trustee of the bankruptcy estate because … administration would be impossible if the trustee had to answer at every step to the bankrupt for the exercise of his powers and discretions in the management of and realisation of the property”: Bramston at 1737, cited in Jonathan Zhang at [31].

18 However, for the following two reasons, I do not accept that the perversity standard applies to a court’s review of the Official Assignee’s decision in respect of a proof of debt.

19 First, it is well-established that the perversity standard does not apply to a court’s review of a private trustee’s decision in respect of a proof of debt. Instead, a de novo review of the proof of debt is undertaken by the court: Shim Wai Han v Lai Seng Kwoon [2025] 4 SLR 876 (“Shim Wai Han”) at [10]; SME Care Pte Ltd v Chan Siew Lee Jannie [2025] SGHC 27 (“SME Care”) at [15]. The appeal against the decision in SME Care was allowed in Yit Chee Wah v Fulcrum Distressed Partners Ltd [2026] 1 SLR 1 (“Fulcrum Distressed Partners”), but the appellate court did not disapprove of the test applied. The High Court in SME Care (at [15]) cited Thomson Plaza (Pte) Ltd v Liquidators of Yaohan Department Store Singapore Pte Ltd [2001] 2 SLR(R) 483 (“Thomson Plaza”) at [15] for the proposition that the court should undertake a de novo review of the validity of a proof of debt. In turn, the court in Thomson Plaza cited Re Kentwood Constructions Ltd [1960] 1 WLR 646 (“Kentwood Constructions”), in which Buckley J held that where a court faces an application to review a liquidator’s decision regarding a proof of debt, the court “must approach the question de novo and determine to what extent the claimants ought to be allowed to rank as a proving creditor” (at 648).

20 It has been observed in a different context that the duties of a private trustee and the Official Assignee are “materially similar”, since both “supervise the conduct and affairs of the bankrupt” and “administer the estate of the bankrupt”: Mirmohammadali Hadian v Ambika d/o Ramachandran [2023] 5 SLR 1153 (“Mirmohammadali”) at [24]. The High Court in Mirmohammadali relied on, inter alia, s 39(1) of the IRDA in support of this. I note that s 36(1) of the BA is substantively similar to s 39(1) of the IRDA; both provisions provide that – subject to certain exceptions – a private trustee in bankruptcy has “all the functions and duties of the Official Assignee” in relation to the conduct of the bankrupt and the administration of the bankrupt’s estate. In my view, the same standard of review (ie, a de novo review) should apply to the decisions of private trustees and the Official Assignee as to proofs of debt, given the material similarity between their duties vis-à-vis a bankrupt and his/her estate.

21 I pause at this juncture to consider the argument by counsel for the Official Assignee, that a different approach should be adopted when a bankrupt applies for a court’s review of the Official Assignee’s decision to admit a proof of debt under s 31 of the BA (as opposed to when a creditor applies for such a review under r 198 of the BR). No authority was provided by counsel for such a proposition. Indeed, SME Care involved, inter alia, an application by the bankrupt to set aside the private trustee in bankruptcy’s partial admission of a proof of debt (SME Care at [2]), yet reliance was placed by the court on Thomson Plaza, which pertained to a creditor’s application to challenge the liquidators’ rejection of its proof of debt (SME Care at [15]).

22 In my view, there is no principled basis to apply a different standard of review simply because a challenge as to a decision on a proof of debt is brought by a bankrupt under s 31 of the BA. There is nothing in the wording of s 31 of the BA – when compared with r 198 of the BR – that demands such an approach to be taken. Further, as counsel for the Official Assignee acknowledged, there is no equivalent of r 198 of the BR (on a creditor’s appeal against a decision on proof) for bankrupts, who must instead rely on s 31 of the BA to seek review of a decision on proof. I highlight that although r 201(1)(b) of the BR provides that the court may expunge a proof of debt on the application of a bankrupt, that avenue is only available “in the case of a composition or scheme”, and therefore was not applicable in the present case. In short, I did not view an application under s 31 of the BA as necessarily requiring a different standard to be applied when compared with an application under r 198 of the BR. What is of greater importance in determining the applicable standard of review is the nature of the Official Assignee’s decision that is sought to be reviewed (which I address at [24]–[29] below).

23 This is fortified by Buckley J’s observation in Kentwood Constructions (at 648) that under r 108 of the Companies (Winding-Up) Rules 1949 (UK), on an application by a creditor or contributory who was dissatisfied with the liquidator’s decision on a proof of debt, the court could “vary [the liquidator’s decision] in any way [that the court] thinks necessary in the light of the evidence before the court”. This was said to reinforce the decision that “[i]t is not merely the function of the court to say that a decision is right or wrong”. In a similar vein, s 31(2)(a) of the BA allows the court to not just “confirm” or “reverse” the Official Assignee’s decision, but also “modify” it where appropriate (see [14] above). This supports the conclusion above that a de novo review of the Official Assignee’s decision in respect of a proof of debt is required.

24 Second, as a matter of first principles, the rationale for applying the perversity standard does not sit well with the proof of debt regime. The perversity standard was adopted to enable a private trustee in bankruptcy (and similarly the Official Assignee) to continue day-to-day administration of the bankrupt’s estate, while ensuring that the “general commercial and business judgment” being exercised remains subject to the court’s review (Jonathan Zhang at [44]) (see also [16]–[17] above). Therefore, to take an example, in holding that the perversity standard applied to a court’s review of a private trustee’s determination of monthly contribution and target contribution, it was held in Haotanto Anna Vanessa v Fang Ching Wen Ted [2023] 3 SLR 1155 that such decisions by the private trustee were made as “part and parcel of [the private trustee’s] administration of the [b]ankrupt’s estate” (at [24]).

25 The proof of debt regime, in my view, involves a different exercise. It is not a balancing exercise but one directed at determining a fact, namely whether and in what amount an alleged debt is to be admitted. This is so even if, under the circumstances, for cost or other considerations, the case is one where the determination may be made in a summary or approximate way. As such, decisions as to proofs of debt do not merely involve the day-to-day administration of the bankrupt’s estate, and a different standard of review is warranted for a court’s review of such decisions. I explain.

26 The starting point is that pursuant to s 76(1)(a) of the BA, once a bankruptcy order is made, the bankrupt’s property vests in the Official Assignee and becomes divisible among his/her creditors. A creditor bears the burden of proving the debt that he/she is owed on a balance of probabilities, and the Official Assignee or trustee in bankruptcy (as the case may be) has to examine the proof of debt and decide whether to admit or reject it (in whole or in part), or require further evidence to be provided: r 197(1) of the BR; see also SME Care at [12]–[13].

27 When admitting or rejecting proofs of debt, the Official Assignee (or the trustee in bankruptcy, as the case may be) exercises a quasi-judicial role: Shim Wai Han at [1]; see also Michael Murray and Jason Harris, Keay’s Insolvency: Personal and Corporate Law and Practice (Thomson Reuters, 11th ed, 2022) at para 6.515, citing the decision of the High Court of Australia in Tanning Research Laboratories Inc v O’Brien (1990) 169 CLR 332. The court in Feima International (Hongkong) Ltd v Kyen Resources Pte Ltd [2024] 4 SLR 101 observed that a liquidator’s quasi-judicial role in assessing proof of debts ensures the “efficiency of the liquidation process” since the liquidator does not need to resolve every dispute in court and is entitled to “oversee simple disputes of facts in order to ensure a practical and efficient conclusion of the liquidation process” (at [48]–[50] and [57]). Although this explanation was provided in the context of liquidators adjudicating proofs of debt in corporate insolvencies, it was affirmed in the context of personal insolvency proceedings in Fulcrum Distressed Partners at [59]–[62].

28 Further, in the corporate insolvency context, it has been explained that the adjudication of a proof of debt does not merely involve “making a commercial decision” (MWA Capital Pte Ltd v Ivy Lee Realty Pte Ltd [2017] SGHC 216 at [44]), and verifying a proof of debt is “not a mere administrative function” (Fustar Chemicals Ltd (Hong Kong) v Liquidator of Fustar Chemicals Pte Ltd [2009] 4 SLR(R) 458 at [20]). Instead, the liquidator’s decision is made in his/her quasi-judicial capacity, and can be set aside by the court “on the basis that it was wrong”, based on “the evidence before [the court] at the time of the application”: Park Hotel Group Management Pte Ltd v Aw Eng Hai [2026] 3 SLR 777 at [13]–[14]. In a similar vein, it has been held that the court hearing an appeal against a liquidator’s decision on proof of debt is “entitled to consider the validity of the proof de novo”: Inner Mongolia at [47]. This also means that the court is not restricted to the material placed before the initial decision-maker (whether it be the judicial manager or the liquidator): ERPIMA SA v Chee Yoh Chuang [1997] 1 SLR(R) 923 at [6].

29 In my view, these observations are equally applicable to an Official Assignee’s (or the trustee in bankruptcy’s) decisions concerning proofs of debt in personal insolvency proceedings. That such decisions are made in a quasi-judicial capacity, coupled with the importance of the proof of debt regime in ensuring an efficient bankruptcy process, sufficiently distinguishes decisions on proofs of debt from day-to-day administrative decision-making that attracts the perversity standard of review by the court.

30 To sum up, a court must hear a bankrupt’s application under s 31 of the BA for review of the Official Assignee’s decision to admit or reject a proof of debt (in whole or in part) de novo, based on the evidence before it at the time of the application. Indeed, in so far as the Official Assignee sought to draw my attention to documents and correspondence dated after the date of its initial decision to admit LSI’s proof of debt (see [33] below), that amounted to an implicit acknowledgement that a court hearing an application under s 31 of the BA is not restricted to the materials before the Official Assignee when it made its initial decision.

31 I now turn to apply these principles to the present case.

32 The Applicant submitted that the Official Assignee had erred in admitting LSI’s proof of debt on 18 June 2020, ¹⁴ based on a letter dated 28 May 2020 from counsel for LSI (“LSI’s May 2020 Letter”). This letter stated that based on confirmation provided by AMP’s own solicitors, a statutory demand had been issued against AMP in 2018 and there were plans to wind up AMP. It was thus proposed that the AMP shares be valued at zero, and the Official Assignee admit LSI’s debt in the value of $839,886.85 “without requiring that the parties seek leave of court to continue with the assessment of damages proceedings in Suit 1311”. ¹⁵ The problem, according to the Applicant, was that an independent valuation of the current value of AMP shares had not been conducted by the Official Assignee. The decision to admit LSI’s proof of debt should be reversed, with the Official Assignee required to undertake a de novo adjudication of the proof, and give written reasons for its eventual decision.

33 The Official Assignee acknowledged that its decision to admit LSI’s proof of debt was based on LSI’s May 2020 Letter, although it was open to reviewing LSI’s admitted proof of debt in the light of a valuation report dated 14 July 2025 (“Valuation Report”) that the Applicant had previously provided. ¹⁶ The Valuation Report provided (at paragraph 1.2) that as of 31 December 2019, AMP was valued at between $17.7 million and $23.6 million, with a “mid-range” valuation of $20.6 million. At the hearing before me, counsel for the Official Assignee clarified the sequence of events to date:

(a) On 4 December 2025, the Applicant wrote to the Official Assignee, seeking its position on (inter alia) LSI’s admitted proof of debt, and whether it was open to reviewing this admission in the light of the Valuation Report.

(b) On 2 January 2026, the Official Assignee informed the Applicant (inter alia) that it was “presently reviewing” the Valuation Report.

(c) On 6 April 2026, the Official Assignee wrote to the Applicant, highlighting various issues with the Valuation Report related to AMP’s valuation, and requesting for further information from the Applicant.

(d) On 20 April 2026, the Applicant replied, stating that he did not have “any separate supplementary report or further written explanation from the valuer”, apart from the Valuation Report. Even so, he reiterated his request that the Official Assignee review LSI’s admitted proof of debt.

(e) On 11 May 2026, the Official Assignee informed the Applicant that since he had no further explanation and relied on the Valuation Report as submitted, it saw no basis to review its earlier decision to admit LSI’s proof of debt.

34 Considering LSI’s proof of debt de novo, I found that that proof was properly admitted based on the evidence that was available before me, and therefore there was no basis to disturb the Official Assignee’s decision on this issue.

35 First, the Applicant’s argument at the hearing before me – that LSI had not discharged its burden of proof to show that the value of the AMP shares was zero – did not hold water. LSI’s May 2020 Letter had made clear that according to AMP’s solicitors, a statutory demand had been issued against AMP in 2018, and that there were plans to wind up AMP’s affairs. That supported the assessment that AMP’s shares had zero value. The Applicant did not appear to dispute this, and indeed, he made clear that he did not allege bad faith or dishonesty in respect of LSI’s May 2020 Letter. ¹⁷ His position, instead, was that the decision to accord the AMP shares zero value was made as a “time-and-cost-saving route”, and the admission of LSI’s proof was “unsafe” as LSI was not required to prove the value of the AMP shares. ¹⁸ However, there is no legal basis for the Applicant’s demand that the Official Assignee conduct or arrange an independent valuation of the AMP shares. LSI’s May 2020 Letter (at paragraph 15) set out the breakdown for the sum of $839,886.85 that was said to be owed to LSI, and in the absence of any contrary evidence, I agreed that the burden of proving the debt owed on a balance of probabilities was discharged by LSI. Since I was entitled to consider all evidence currently before me in the present de novo review, I found that one relevant consideration in admitting LSI’s proof of debt was the fact that the Applicant had logged onto the Insolvency Office’s online portal on 23 June 2020 and admitted to LSI’s proof of debt for the sum of $839,886.85. ¹⁹ While the Official Assignee had admitted a proof of debt in the sum of $826,966.99, and there was no material before me to account for the difference from the sum proposed in LSI’s May 2020 Letter, I was satisfied that the (lower) admitted proof was in fact in favour of the estate of the bankrupt, and thus did not provide a basis to reverse or modify the Official Assignee’s decision.

36 Second, having reviewed the Valuation Report, I agreed with the issues highlighted by the Official Assignee in its letter to the Applicant dated 6 April 2026. In particular, paragraph 1.1 of the Valuation Report provided that the valuer had relied on the audited financial statements of AMP for the financial years ending in 2015, 2016 and 2017, yet the valuation date was 31 December 2019 (see paragraph 2.7). The valuer assumed that the cashflows for 2018 and 2019 continued “in the same vein as 2017” (see paragraphs 2.11 and 5.3), but no supporting evidence was provided by the valuer for this bare assertion. Indeed, the valuer acknowledged that the valuation was conducted without visiting AMP’s facilities, without inspecting any of AMP’s intangible assets and without conducting any interviews (see Valuation Report at paragraphs 3.1–3.3).

37 At the hearing before me, the Official Assignee submitted that the financial statements of AMP and its subsidiary (Aesthetic Medical Holdings Pte Ltd, “AMH”) showed that AMP was dormant since December 2018, and also that the assets of AMP and AMH had been transferred to other companies. Similar points had been made in the Official Assignee’s letter to the Applicant dated 6 April 2026. Counsel for the Official Assignee rightly conceded that these financial statements were not in evidence before me. Be that as it may, the fact remained that the Applicant was given an opportunity to account for the discrepancies in the Valuation Report. Yet not only did he fail to dispute the issues raised by the Official Assignee, but there was also no explanation forthcoming from the Applicant (see [33(d)] above).

38 In the circumstances, I was satisfied that the Valuation Report provided no basis to reverse or modify the Official Assignee’s decision in respect of LSI’s proof of debt under s 31(2)(a) read with s 31(1) of the BA. For completeness, I add that if I was wrong on the applicable test as summarised at [30] above, and the (lower) perversity standard in fact applied to the present case, then a fortiori, there would be no basis to disturb the Official Assignee’s decision on LSI’s proof of debt.

39 For these reasons, there was no basis to allow the Applicant’s claim in Schedule C of OA 101 in respect of LSI’s proof of debt. As noted above, neither was there any reason to allow the Applicant’s claims in Schedules A and B of OA 101. I thus dismissed OA 101 and fixed costs at $4,000 all-in, payable by the Applicant to the Official Assignee.