LEONG QUEE CHING KAREN v LIM SOON HUAT & 5 Ors
Key facts
| Court | High Court (General Division) |
|---|---|
| Decided | |
| Judge | Goh Yihan |
| Charges / claim | Civil Procedure, Abuse of Process |
| Counsel | Ark Law Corporation, Selvam LLC, Tan Kok Quan Partnership, UniLegal LLC, Eugene Jedidiah Low Yeow Chin, Lee Pei Hua Rachel, Loh Li Qin, Natalie Ng Hai Qi, Ng Ka Luon Eddee, Roshan Singh Chopra, Sakthi Vel s/o Raman, Sarbjit Singh Chopra, Tan Teng Muan, Tnee Zixian Keith |
Source: [2023] SGHC 234, High Court (General Division), decided — eLitigation. Updated .
Catchwords
Practice Areas
Judges (1)
Counsel (14)
Case Significance
Leong Quee Ching Karen v Lim Soon Huat and others [2023] SGHC 234 is a reserved judgment of Goh Yihan JC in the General Division of the High Court, delivered on 23 August 2023 in Originating Claim No 158 of 2022 (Summons No 3376 of 2022). The claimant, Ms Leong Quee Ching Karen, a minority shareholder of the sixth defendant Seng Lee Holdings Pte Ltd, commenced HC/OC 158/2022 against the majority shareholders for alleged minority oppression and had sought an interlocutory injunction to restrain the transfer of certain properties. In the present application she sought to strike out email correspondence and related paragraphs exhibited in affidavits opposing that injunction, which she alleged were protected by "without prejudice" privilege; the judgment addresses without prejudice privilege, waiver, the Muller exception and non approbation and reprobation.
[2023] SGHC 234 explained
LEONG QUEE CHING KAREN v LIM SOON HUAT & 5 Ors ([2023] SGHC 234) is a Singapore judgment decided by the High Court (General Division) on 23 August 2023. It is categorised under Civil Procedure and Abuse of Process. Within this corpus it has since been cited by 1 other reported Singapore judgment, a measure of how often later decisions have referred to it. This page summarises what the reported decision covers and links the primary sources — the full judgment, the statutes it cites, and the other cases it engages with — so the decision can be read in context. It is reference information, not legal advice, and it does not state the outcome or any holding beyond what the official judgment records.
What is [2023] SGHC 234 about?
LEONG QUEE CHING KAREN v LIM SOON HUAT & 5 Ors ([2023] SGHC 234) is a High Court (General Division) decision from 2023. Its published catchwords are “Civil Procedure — Privileges — Waiver”, “Civil Procedure — Privileges — Muller exception”, “Civil Procedure — Privileges — Without prejudice privilege”, and “Abuse of Process — Inconsistent positions — Non approbation and reprobation”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.
Which legislation does [2023] SGHC 234 consider?
The judgment refers to Evidence Act (Cap 97). The statutes cited are listed in full on this page, each linking to its primary text.
What earlier Singapore cases does [2023] SGHC 234 cite?
Among the in-corpus authorities it refers to are [2023] SGHC 24. The complete list of cases cited, and of later cases that cite this decision, is shown on this page.
How influential is [2023] SGHC 234?
Within this corpus, [2023] SGHC 234 has been cited by 1 later reported Singapore judgment. That count reflects references from other decisions held in this corpus only and is a conservative lower bound on how often the case has actually been cited.
Summary
Leong Quee Ching Karen, a minority shareholder of Seng Lee Holdings Pte Ltd, brought minority oppression proceedings against the majority shareholders and applied to strike out email correspondence exhibited in affidavits opposing an injunction, arguing the emails were protected by "without prejudice" privilege. The court considered the privilege and the doctrine of approbation and reprobation. It allowed the application, expunging all the emails save for one sent by Mr Wee on 9 November 2020, and ordered the affected affidavits to be refiled.
What was Leong Quee Ching Karen v Lim Soon Huat [2023] SGHC 234 about?
It was an application before Goh Yihan JC by minority shareholder Leong Quee Ching Karen to strike out email correspondence exhibited in affidavits, which she alleged was protected by "without prejudice" privilege, in a minority oppression claim, decided on 23 August 2023.
What privilege issues arose in [2023] SGHC 234?
The judgment addressed without prejudice privilege, waiver of privilege, the Muller exception, and the abuse of process principle against approbation and reprobation, in relation to emails exhibited by majority shareholders opposing the claimant's injunction application.
Statutes Cited
Cases Cited (38)
Related cases
Other Singapore judgments involving the same parties or counsel.
Referenced in
Statutes interpreted in this judgment
Legal concepts & references
Judgment
Read the full judgment on the official Singapore Courts portal.
Read on eLitigationSource: eLitigation ([2023] SGHC 234)