JANE REBECCA ONG v Estate of LIM LIE HOA ALSO KNOWN AS LIM LE HOA ALSO KNOWN AS LILY ARIEF HUSNI, deceased

Q: Which legislation does [2023] SGHC 33 consider?

The judgment refers to Banking Act, Bankruptcy Act (Cap 20), Bankruptcy Ordinance, and Companies Act (Cap 50), among other provisions. The statutes cited are listed in full on this page, each linking to its primary text.

[2023] SGHC 33 High Court (General Division) 15 February 2023 HC/B 2704/2020 ( HC/SUM 4145/2022,HC/SUM 4139/2022,HC/SUM 4144/2022 ) 25 min read

7 cases cited (6 SG, 1 foreign)

Outcome

Application granted

I granted the Applications sought.

Source: [2023] SGHC 33, High Court (General Division), decided 15 February 2023. Read directly from the judgment.

Key facts

Court	High Court (General Division)
Decided	15 February 2023
Judge	Goh Yihan
Charges / claim	Banking, Insolvency Law
Outcome	Application granted
Counsel	Allen & Gledhill LLP, BlackOak LLC, Balakrishnan Ashok Kumar, Gloria Chan Hui En, Ivan Lim, Stanley Tan Sing Yee

Source: [2023] SGHC 33, High Court (General Division), decided 15 February 2023 — eLitigation. Updated 10 July 2026.

Catchwords

Banking — Banker’s books — Proceedings — Civil Insolvency Law — Bankruptcy — Trustee in bankruptcy — Inspection of bankers’ books — Whether principles applicable to inquiry of company’s dealings is also applicable to examination of bankrupt and others

Practice Areas

Banking Insolvency Law

Judges (1)

Goh Yihan Delivered

Counsel (6)

Allen & Gledhill LLP Firm BlackOak LLC Firm Balakrishnan Ashok Kumar Counsel Applicant Gloria Chan Hui En Counsel Applicant Ivan Lim Counsel Respondent Stanley Tan Sing Yee Counsel Applicant

Parties (5)

Citibank Singapore Limited Respondent Oversea-Chinese Banking Corporation Limited Respondent United Overseas Bank Limited Respondent Jane Rebecca Ong Plaintiff Lim Lie Hoa also known as Lim Le Hoa also known as Lily Arief Husni Defendant

Case Significance

Ong Jane Rebecca v Lim Lie Hoa [2023] SGHC 33 sets out the General Division of the High Court's grounds of decision in Bankruptcy No 2704 of 2020, involving Summonses Nos 4139, 4144 and 4145 of 2022, delivered by Goh Yihan JC on 15 February 2023 after a hearing on 17 January 2023. The applicants were the joint and several private trustees of the estate of the deceased debtor, Mdm Lim Lie Hoa (also known as Lim Le Hoa and as Lily Arief Husni), who applied under s 335 of the Insolvency, Restructuring and Dissolution Act 2018 against three banks — Citibank Singapore Limited, Oversea-Chinese Banking Corporation Limited and United Overseas Bank Limited respectively. The main prayer sought an order for inspection of bankers' books under s 175 of the Evidence Act 1893 read with s 47 of the Banking Act 1970, raising whether principles applicable to a company's dealings extend to examining a bankrupt.

[2023] SGHC 33 explained

JANE REBECCA ONG v Estate of LIM LIE HOA ALSO KNOWN AS LIM LE HOA ALSO KNOWN AS LILY ARIEF HUSNI, deceased ([2023] SGHC 33) is a Singapore judgment decided by the High Court (General Division) on 15 February 2023. It is categorised under Banking and Insolvency Law. It is a recent decision; within this corpus no later judgment has cited it yet. 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 33 about?

JANE REBECCA ONG v Estate of LIM LIE HOA ALSO KNOWN AS LIM LE HOA ALSO KNOWN AS LILY ARIEF HUSNI, deceased ([2023] SGHC 33) is a High Court (General Division) decision from 2023. Its published catchwords are “Banking — Banker’s books — Proceedings — Civil” and “Insolvency Law — Bankruptcy — Trustee in bankruptcy — Inspection of bankers’ books — Whether principles applicable to inquiry of company’s dealings is also applicable to examination of bankrupt and others”, 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 33 consider?

The judgment refers to Banking Act, Bankruptcy Act (Cap 20), Bankruptcy Ordinance, and Companies Act (Cap 50), among other provisions. The statutes cited are listed in full on this page, each linking to its primary text.

Summary

The joint private trustees of the bankrupt estate of the late Lim Lie Hoa applied under s 335 of the Insolvency, Restructuring and Dissolution Act 2018 for orders allowing them to inspect and take copies of bankers' books held by three banks. The court considered whether principles governing an inquiry into a company's dealings applied to the examination of a bankrupt and others. Goh Yihan JC granted the applications, finding the bank statements were reasonably required for the trustees' investigations and could be disclosed.

What did the trustees seek in Ong Jane Rebecca v Lim Lie Hoa ([2023] SGHC 33)?

The private trustees of the estate of the late Mdm Lim Lie Hoa applied under s 335 of the IRDA for orders to inspect bankers' books held by Citibank Singapore Limited, OCBC and United Overseas Bank Limited, under s 175 of the Evidence Act.

Which banks were respondents in [2023] SGHC 33?

The three respondents were Citibank Singapore Limited, Oversea-Chinese Banking Corporation Limited and United Overseas Bank Limited. The trustees' applications, in Bankruptcy No 2704 of 2020, were heard by Goh Yihan JC on 17 January 2023.