Aaron Loh Cheng Lee & Anor v HODLNAUT PTE. LTD.

Q: Which legislation does [2023] SGHC 323 consider?

The judgment refers to Companies Act (Cap 50), Insolvency, Restructuring and Dissolution Act, Payment Services Act, and Restructuring and Dissolution Act. The statutes cited are listed in full on this page, each linking to its primary text.

[2023] SGHC 323 High Court (General Division) 10 November 2023 HC/CWU 94/2023 11 min read

1 cases cited Cited by 1 case

Outcome

Application granted

I grant the application to wind up the Company.

Source: [2023] SGHC 323, High Court (General Division), decided 10 November 2023. Read directly from the judgment.

Key facts

Court	High Court (General Division)
Decided	10 November 2023
Judge	Aedit Abdullah
Charges / claim	Insolvency Law
Outcome	Application granted
Counsel	Adelphi Law Chambers LLC, CHP Law LLC, Damodara Ong LLC, Rajah & Tann Singapore LLP, WongPartnership LLP, Andrew Pflug, Ang Peng Koon Patrick, Chan Daniel, Chng Qi Yun Clarice, Darius Malachi Lim Wen Hong, Ho Zi Wei, Kang Kok Boon, Favian, Leo Zhen Wei Lionel, Leonard Chua Jun Yi, Li Yiling Eden, Lim Dao Yuan Keith, Manoj Pillay Sandrasegara, Md Noor E Adnaan, Ning Jie, Ong Hui Jing, Ong Ziying Clement, Quah Wei Sheng Danny, Raelene Pereira, Ramesh Chandra, S.M. Sukhmit Singh, Stephanie Yeo Xiu Wen, Suresh s/o Damodara, T Abirami, Toh Yong Xiang, Wee Min, Wong Ye Yang

Source: [2023] SGHC 323, High Court (General Division), decided 10 November 2023 — eLitigation. Updated 10 July 2026.

Catchwords

Insolvency Law — Winding up — Liquidator — Directors alleging wrongdoing by interim judicial managers — Whether interim judicial managers should be appointed liquidators Insolvency Law — Winding up — Grounds for petition — Directors of company seeking restructuring of company — Whether court should exercise its discretion to wind up company — Section 125(1) Insolvency, Restructuring and Dissolution Act 2018 (2020 Rev Ed) Insolvency Law — Winding up — Grounds for petition — Company owing cryptocurrency liabilities — Whether company unable to pay its debts — Whether liability to pay cryptocurrency was a debt for the purposes of a winding up application — Sections 125(1)(e) and 125(2)(c) Insolvency, Restructuring and Dissolution Act 2018 (2020 Rev Ed) Insolvency Law — Winding up — Grounds for petition — Company owing cryptocurrency liabilities — Whether company unable to pay its debts — Whether a halt by the company on customers withdrawing cryptocurrency showed that there was no liability to pay cryptocurrency — Sections 125(1)(e) and 125(2)(c) Insolvency, Restructuring and Dissolution Act 2018 (2020 Rev Ed)

Practice Areas

Insolvency Law

Judges (1)

Aedit Abdullah Delivered

Counsel (31)

Parties (9)

Algorand Foundation Ltd Third Party Hodlnaut Pte Ltd Defendant Official Receiver Third Party S.A.M. Fintech Pte Ltd (in liquidation) Third Party Samtrade Custodian Limited (in liquidation) Third Party Aaron Loh Cheng Lee Plaintiff Ee Meng Yen Angela Plaintiff Simon Eric Lee Third Party Zhu Juntao Third Party

Case Significance

Loh Cheng Lee Aaron and another v Hodlnaut Pte Ltd (Zhu Juntao and others, non-parties) [2023] SGHC 323 is a judgment of the General Division of the High Court delivered by Aedit Abdullah J on 10 November 2023 in Companies Winding Up No 94 of 2023. Brought by directors Aaron Loh Cheng Lee and Ee Meng Yen Angela, the case examined an application to wind up crypto-lending firm Hodlnaut under s 125(1)(e) of the Insolvency, Restructuring and Dissolution Act 2018. Central questions were whether a liability to pay cryptocurrency constituted a debt for winding-up purposes, whether a halt on customer withdrawals showed no such liability, and whether interim judicial managers alleged to have committed wrongdoing should be appointed liquidators. The judgment cites four statutes.

[2023] SGHC 323 explained

Aaron Loh Cheng Lee & Anor v HODLNAUT PTE. LTD. ([2023] SGHC 323) is a Singapore judgment decided by the High Court (General Division) on 10 November 2023. It is categorised under Insolvency Law. 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 323 about?

Aaron Loh Cheng Lee & Anor v HODLNAUT PTE. LTD. ([2023] SGHC 323) is a High Court (General Division) decision from 2023. Its published catchwords are “Insolvency Law — Winding up — Liquidator — Directors alleging wrongdoing by interim judicial managers — Whether interim judicial managers should be appointed liquidators”, “Insolvency Law — Winding up — Grounds for petition — Directors of company seeking restructuring of company — Whether court should exercise its discretion to wind up company — Section 125(1) Insolvency, Restructuring and Dissolution Act 2018 (2020 Rev Ed)”, “Insolvency Law — Winding up — Grounds for petition — Company owing cryptocurrency liabilities — Whether company unable to pay its debts — Whether liability to pay cryptocurrency was a debt for the purposes of a winding up application — Sections 125(1)(e) and 125(2)(c) Insolvency, Restructuring and Dissolution Act 2018 (2020 Rev Ed)”, and “Insolvency Law — Winding up — Grounds for petition — Company owing cryptocurrency liabilities — Whether company unable to pay its debts — Whether a halt by the company on customers withdrawing cryptocurrency showed that there was no liability to pay cryptocurrency — Sections 125(1)(e) and 125(2)(c) Insolvency, Restructuring and Dissolution Act 2018 (2020 Rev Ed)”, 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 323 consider?

The judgment refers to Companies Act (Cap 50), Insolvency, Restructuring and Dissolution Act, Payment Services Act, and Restructuring and Dissolution Act. The statutes cited are listed in full on this page, each linking to its primary text.

How influential is [2023] SGHC 323?

Within this corpus, [2023] SGHC 323 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

This was an application to wind up Hodlnaut Pte Ltd, a Singapore company that had held cryptocurrency from creditors and had earlier been placed under interim judicial management. The central issues were whether cryptocurrency obligations counted as debts under the Insolvency, Restructuring and Dissolution Act 2018 and whether the company was cash-flow insolvent. The court held the company was insolvent, ordered it wound up, and appointed the interim judicial managers as liquidators.

What was Loh Cheng Lee Aaron v Hodlnaut Pte Ltd [2023] SGHC 323 about?

It was a General Division of the High Court winding-up matter decided by Aedit Abdullah J on 10 November 2023, addressing whether crypto firm Hodlnaut's cryptocurrency liabilities amounted to a debt under s 125(1)(e) of the Insolvency, Restructuring and Dissolution Act 2018.

Did the Hodlnaut [2023] SGHC 323 case consider who should be appointed liquidator?

Yes. Among the winding-up issues in Companies Winding Up No 94 of 2023, the court considered whether interim judicial managers, whom the directors alleged had committed wrongdoing, should be appointed liquidators of Hodlnaut Pte Ltd.