CSO v CSP & Anor

Q: Which legislation does [2023] SGHC 24 consider?

The judgment refers to Evidence Act (Cap 97) and Patents Act (Cap 221). The statutes cited are listed in full on this page, each linking to its primary text.

[2023] SGHC 24 High Court (General Division) 8 February 2023 HC/OS 268/2022 ( HC/RA 219/2022 ) 35 min read

15 cases cited (9 SG, 6 foreign) Cited by 2 cases

Key facts

Court	High Court (General Division)
Decided	8 February 2023
Judge	Andre Maniam
Charges / claim	Evidence, Civil procedure
Counsel	JWS Asia Law Corporation, MPillay, Rajah & Tann Singapore LLP, Ang Leong Hao, Ang Wee Jian, Glenn Sim Sze Nyuang, Kwek Yuan Justin, Sia Bao Huei, Tan Hao Ting Valerie, Tan Hong Liang, Toh Chen Han, Wayne Yeo, Wong Soon Peng Adrian

Source: [2023] SGHC 24, High Court (General Division), decided 8 February 2023 — eLitigation. Updated 10 July 2026.

Catchwords

Evidence — Admissibility of evidence Evidence — Proof of evidence — Admissions Civil procedure — Privileges — Without prejudice privilege

Practice Areas

Evidence Civil procedure

Judges (1)

Andre Maniam Delivered

Counsel (13)

JWS Asia Law Corporation Firm MPillay Firm Rajah & Tann Singapore LLP Firm Ang Leong Hao Counsel Plaintiff Ang Wee Jian Counsel Defendant Glenn Sim Sze Nyuang Counsel Defendant Kwek Yuan Justin Counsel Defendant Sia Bao Huei Counsel Plaintiff Tan Hao Ting Valerie Counsel Defendant Tan Hong Liang Counsel Defendant Toh Chen Han Counsel Defendant Wayne Yeo Counsel Plaintiff Wong Soon Peng Adrian Counsel Plaintiff

Parties (3)

CSO Plaintiff CSP Defendant CSQ Defendant

Case Significance

CSO v CSP and another [2023] SGHC 24 is a Grounds of Decision of the General Division of the High Court, delivered by Andre Maniam J on 8 February 2023 in Originating Summons No 268 of 2022 (Registrar's Appeal No 219 of 2022). The judgment addresses the admissibility of evidence, admissions, and the without prejudice privilege attaching to communications made in the course of settlement negotiations. Discussing authorities including Nicky Quek, Mariwu, Cutts v Head and Rush & Tompkins, the court considers the policy of encouraging parties to settle disputes without resort to litigation. The record notes 15 citing references (nine Singapore, six foreign) and reference to the Evidence Act and Patents Act.

[2023] SGHC 24 explained

CSO v CSP & Anor ([2023] SGHC 24) is a Singapore judgment decided by the High Court (General Division) on 8 February 2023. It is categorised under Evidence and Civil procedure. Within this corpus it has since been cited by 2 other reported Singapore judgments, 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 24 about?

CSO v CSP & Anor ([2023] SGHC 24) is a High Court (General Division) decision from 2023. Its published catchwords are “Evidence — Admissibility of evidence”, “Evidence — Proof of evidence — Admissions”, and “Civil procedure — Privileges — Without prejudice privilege”, 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 24 consider?

The judgment refers to Evidence Act (Cap 97) and Patents Act (Cap 221). The statutes cited are listed in full on this page, each linking to its primary text.

How influential is [2023] SGHC 24?

Within this corpus, [2023] SGHC 24 has been cited by 2 later reported Singapore judgments. 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

In this registrar's appeal, CSO disputed with CSP and CSQ whether five emails exchanged during settlement negotiations were protected by "without prejudice" privilege under the common law and section 23 of the Evidence Act. The issue was whether the whole of the communications were privileged and whether an exception permitted reference to parts of them. The court held the emails were protected under the broad approach but dismissed the appeal, allowing the first defendant to refer only to limited portions rebutting the plaintiff's assertions.

What issue did CSO v CSP [2023] SGHC 24 address?

The General Division of the High Court, per Andre Maniam J, considered the admissibility of evidence and the without prejudice privilege over settlement communications in Originating Summons No 268 of 2022 (Registrar's Appeal No 219 of 2022), decided 8 February 2023.

Which court and judge decided [2023] SGHC 24?

The matter was heard in the General Division of the High Court of Singapore before Andre Maniam J. The case was heard on 8 August 2022 and the Grounds of Decision were delivered on 8 February 2023, with parties represented by Rajah & Tann Singapore LLP, JWS Asia Law Corporation and MPillay.