1. These are my grounds of decision in the applications by the Applicant for Personal Protection Orders against her which were filed on 24 September 2025.

(a) SSP xxx of 2025 – Mother

(b) SSP xxx of 2025 – Father

(c) SSP 1899 of 2025 – Sister

2. For context, I note that the above applications were heard together on 14 January 2025 with the Sister’s application in SSP xxx of 2025 against the Applicant, which was filed on 21 October 2025.

3. I dismissed all the Applicant’s applications and ordered the sister’s application in SSP xxx of 2025. The Applicant has filed an appeal on 28 January 2026, but only in respect of SSP 1899 of 2025 against her Sister. The full grounds of my decision for all the applications are set out below.

4. The applications focused specifically on two events which took place on 22 May 2025 and 30 July 2025. At the material time, all four parties lived together. After the 30 July 2025, the Applicant left the home, returning briefly in August 2025 to take her things.

5. Part 7 of the Women’s Charter 1961 (“the Charter”) sets out the principles on Protection Against Family Violence.

6. Section 60A allows the Court to make a protection order to restrain a Respondent from committing family violence against the Applicant is the Court is satisfied, on a balance of probabilities, that:

(a) The Respondent has committed or is likely to commit family violence against the Applicant; and

(b) The protection order is necessary for the protection or personal safety of the Applicant.

7. The definition of what constitutes “family violence” is set out in Section 58B, which is broad in nature and covers a wide range of abuse against a family member which can be physical, sexual, emotional or psychological (Charter s.58B(1)(a),(b)):

(a) “Physical Abuse” includes:

(i) Conduct or behavior that causes or threatens to cause personal injury or physical pain to a person; or threatens a person with death or injury to them (Charter s.58B(2)(a), (b)).

(ii) Wrongfully confiding or restraining a person against their will (Charter s.58B(2)(b)).

However, it does not include force lawfully used in self-defence or by way of correction towards a child under 18 years of age (Charter s.58B(2)(c)(i), (ii)).

(b) “Sexual Abuse” includes conduct or behavior that coerces, or attempts to coerce a person to engage in sexual activity (Charter s.58B(3)).

(c) “Emotional or psychological abuse” means:

(i) conduct or behavior that torments, intimidates, harasses or distresses a person (Charter s.58B(4)(a));

(ii) or cause or may reasonably expected to cause mental harm to a person, including thoughts of suicide or inflicting self-harm (Charter s.58B(4)(b)).

8. The “abuse” in question can take the form of a single instance of conduct or behavior, or a course of conduct or behavior (Charter s.58B(5)(a), (b)). It also does not need to be directed at the Respondent but must be capable of being seen, heard or otherwise perceived (directly or indirectly) by the family member in question Charter s.58B(6). An illustration of such acts under Charter s.58(6) include:

Illustration (a) – Where the Respondent spreads rumours to a third party about the Applicant being promiscuous, which distresses the Applicant. This amounts to emotional or psychological abuse.

Illustration (b) – Where the Respondent smashes furniture at home in front his children, which causes them distress and puts them in fear of personal injury. This amounts to physical, emotional or psychological abuse.

Illustration (c) – Where the Respondent repeatedly makes demeaning comments to belittle and humiliate the Applicant in front of their children, and threatens to stop giving her a monthly allowance if she seeks help, causing her mental harm. This amounts to emotional or psychological abuse.

9. This is a departure from the previous regime which focused on four scenarios of family violence (a) wilfully or knowingly placing or attempting to place a person in fear of hurt (b) causing hurt by an act known or ought to have been known to result in hurt (c) wrongfully confining or restraining a family member against their will (d) continual harassment with intention to cause anguish.

10. The new scenarios of what constitutes family violence recognize a shift towards recognizing the insidious effect of seemingly non-violent or non-specific acts can have on the emotional and psychological state of a person.

11. However, while the new regime casts a wider net to capture a broader spectrum of acts, the safeguard of necessity still remains unchanged. After all, a protection order is not a punitive measure to punish a person for past violence but a preventive measure that serves to restrain the person concerned from committing family violence in future. Therefore, if there is a low likelihood of family violence in the future, it serves no purpose to restrain the party concerned and it must follow that a protection order would not be necessary. Yue Tock Him@Yee Chok Him v Yee Ee Lim [2011] SGDC 99 ¹ (“Yue”) [64].

12.  In assessing necessity, one has to consider all the facts and circumstances involved, but it is useful to focus on the following factors:

(a) The severity and frequency of the family violence concerned.

(b) The nature of the dispute which resulted in the occurrence of family violence.

(c) Are the parties still living together or likely to remain in contact.

13. I will now address the facts and apply the law to them.

14. The Applicant alleges that on 20 May 2025, she noticed that a container in the kitchen of coffee powder she was cultivating as fertilizer had been knocked over. She wanted to confront her sister about it and went up to the second floor of the family home, where her sister’s room was.

15. Her sister refused to engage with her and locked herself in the room. The Applicant proceeded to grab a hammer to hit the door knob until the door bolt sprung open. Once the door opened, both sisters started quarrelling and the Mother had to physically step in between them. It was said by the Applicant that her sister had said hurtful things to her, which prompted the Applicant to reach past her Mother and punch the sister in the face.

16. The punch knocked her sister’s glasses off and this prompted both the Applicant and her sister to scuffle. Here, the Applicant alleges that she was punched and kicked by her sister who grabbed and twisted her arms. Eventually the Father came along and both the Father and Mother had to restrain the Applicant. The Father applied stronger force on the Applicant’s arms which prompted her to dig her nails into his arms, causing him to release his grip on her.

17. During cross examination, the sister admitted to having to grab the Applicant’s hands and pushed her to fight her off, but this only lasted a short while and she quickly went into her room to call the police.

18. The Mother also admitted that she had to step in between both sisters, and that both herself and the Father had to restrain the Applicant.

19. A medical report dated 23 May 2025 observed a tenderness on the Applicant’s right wrist and forearm, with small cuts on her right hand and scratches on her bicep, both fingers, and left forearm. She suffered pain and numbness as well as a reduced range of motion in her right hand which were diagnosed as a soft tissue injury by a hand surgeon who issued a medical report dated 28 May 2025. The report noted that there were no fractures or nerve lesions observed.

20. The Applicant was also sent for an MRI on the affected parts. The results of this MRI and further diagnosis were not produced in evidence.

21. I make a finding that the sister had scuffled with the Applicant after being hit, but this was done in response to the Applicant’s conduct and it was brief. I did not see any evidence in medical report of the Applicant being punched or kicked. These injuries to her arms, forearm, hand and in particular her wrist are more consistent with the restraint applied by the sister, Mother and Father, in particular the Father, to the Applicant.

22. The Applicant alleges that on 30 July 2025, that her sister was standing on the staircase when she made a profane reference to the Applicant, who was in the living room at the time.

23. The Applicant went to approach her sister on the stairs to speak to her about her behavior. During the trial she confirmed that as she moved from the living room to the stairs to confront her sister, she did not utter a word.

24. As the Applicant moved closer to her sister, the sister allegedly used the blender in her hand (which was about 20-25cm in height) to smash the Applicant on her head, and she was hit on her brow and above her eye. Both sisters scuffled and the Applicant put her hands on her sister to pull her down the stairs to the ground floor. She says this was done as it was dangerous to remain on the stairs during the confrontation.

25. Once they were on the ground floor, her sister, Mother and Father were all trying to restrain her by grabbing her arms. The bulk of such restraint was done by the Father, while the sister moved up to her room on the second floor.

26. During the hearing, the sister claimed that she had released the blender and other items in her hands as she tried to defend herself from the Applicant. She admitted that the blender had hit the Applicant as it fell.

27. The Mother also said she saw the Applicant rush up the stairs towards her sister. She rushed out of the kitchen where she was, and after the Applicant as she went up the stairs. When the blender hit the Applicant, the Mother was right behind her and unable to see exactly how it came to hit the Applicant. However she did see both sisters grab each other and the Applicant pulled her sister’s hair, while her sister pulled on her wrists. The Mother grabbed onto the Applicant. At this point, the Father appeared and subsequently restrained the Applicant by grabbing onto her arms. This was despite the Applicant explaining to the Father that there were no issues. At some point, the Father let go of the Applicant, only to grab her by her arms again when she picked up the blender to explain herself.

28. A medical report dated 31 July 2025 observed a minor head injury with a tenderness in her left wrist and thumb. However no fractures were observed. Contemporaneously taken photographs on 31 July 2025 showed some very small cuts, scratches and contusions on her left and right forearm, wrist and hand. There were also bruises on the inner and outer side of her right knee. A further report dated 1 October 2025 noted that she had to be treated with a thumb cast which covered the front half of her forearm, wrist and left thumb. Notably, there were no pictures indicating any marks on her head.

29. The Applicant was also sent for an MRI on the affected parts. The results of this MRI and further diagnosis were not produced in evidence.

30. I make the following findings:

(a) The Applicant had acted aggressively by moving quickly up the stairs to confront her sister without saying anything. Given the recent events of 20 May 2025, it was reasonable for the sister to apprehend that some kind of physical confrontation would occur.

(b) The blender in the sister’s hand was released in a quick decision to defend herself from the Applicant. Notably, there were no significant marks on the Applicant’s head despite her claims that she had been smashed on the head with the blender. This was a sizeable object and if the sister had really hit the Applicant on her head with intent, there would have been visible marks and even greater injury.

(c) Subsequently, the Applicant dragged her sister down the stairs. She claimed that this was done to protect parties from greater harm caused by remaining on the stairs. This would not have been obvious to her sister given her current and past conduct and probably escalated concerns about a physical confrontation.

(d) The sister, Mother and Father all restrained her and that amounts to physical violence, with the Father’s restraint causing greater injury given his strength.

31. It is clear from the evidence that on both occasions in May and July 2025, the Applicant was the aggressor and antagonist. She was the first to use physical violence on her sister on 22 May 2025, and had rushed briskly to confront her sister on the stairs before dragging her down the stairs in their confrontation.

32. Subsequent restraint and physical contact between the sister and Applicant was brief as the Mother and in particular the Father stepped in to restrain the Applicant physically.

33. There was never any risk of the sister, Mother or Father making the first move to physically confront the Applicant. Moreover, the Applicant had moved out of the family home in 30 July 2025, so there would not have been much point in granting a PPO anyway.

34. On this, the Applicant claimed that she would need a PPO as she was concerned the parties would interact when they visited her grandparents. She said she did so regularly, but the other parties did not.

35. I was not convinced there was any necessity. The possibility of such interaction appeared low as the parties’ visiting times did not overlap much. Visiting timings could also be coordinated or determined by contact with the Grandparents.

36. Even if there was a greater degree of interaction, it was the Applicant who was the antagonist and not her family members. Why should a PPO be ordered against them when they were clearly just responding on both occasions to restrain her from further violence? If the Applicant were to reduce her interaction and not escalate matters, there was no risk of them having to respond correspondingly. Therefore I dismissed all the Applicant’s applications for a PPO, including the application against her sister.

37. In respect of the sister’s application in SSP xxx of 2025, I was of the view that the family violence had been made out given the Applicant’s conduct on 20 May 2025 and 30 July 2025. Her conduct on both occasions also indicated that it was necessary for a PPO to be granted as she was likely to antagonize the sister at home. This was contrasted with the conduct of her sister who tended to avoid conflict unless drawn into it by the Applicant. While the Applicant was currently not at living in the family home, I could not be sure that she would subsequently change her mind and return. So I ordered a PPO to restrain the Applicant from inflicted family violence against her sister, to last for a duration of one year. Parties would attend mandatory counselling and I hope that this cooling off period would help them and in particular the Applicant to regulate her emotions and conduct.

38. For the reasons above, I dismissed the following applications - SSP xxx of 2025, SSP xxx of 2025, SSP 1899 of 2025 and granted SSP xxx of 2025.

Goh Zhuo Neng

District Judge