ARIF RAHIM VALIBHOY v MAJLIS UGAMA ISLAM SINGAPURA

[2023] SGHC 341 High Court (General Division) 1 December 2023 HC/OS 1168/2021 ( HC/SUM 1671/2023 )

18 cases cited (12 SG, 6 foreign)

Key facts

Court	High Court (General Division)
Decided	1 December 2023
Judge	Valerie Thean
Charges / claim	Administrative Law, Civil Procedure
Counsel	Breakpoint LLC, Legal Clinic LLC, Rajah & Tann Singapore LLP, Red Lion Circle, Anil Narain Balchandani, Benjamin Tan Zhi Xiong, Chan Xiaohui Darius (Chen Xiaohui), Foo Xian Fong, Kam Su Cheun Aurill, Liew Min Yi Glenna, Poon Guokun Nicholas, Vikram Nair

Source: [2023] SGHC 341, High Court (General Division), decided 1 December 2023 — eLitigation. Updated 10 July 2026.

Catchwords

Administrative Law — Judicial Review Civil Procedure — Parties — Joinder

Practice Areas

Administrative Law Civil Procedure

Judges (1)

Valerie Thean Delivered

Counsel (12)

Breakpoint LLC Firm Legal Clinic LLC Firm Rajah & Tann Singapore LLP Firm Red Lion Circle Firm Anil Narain Balchandani Counsel for the applicant

Benjamin Tan Zhi Xiong Counsel for the respondent

Chan Xiaohui Darius (Chen Xiaohui) Counsel for the respondent

Foo Xian Fong Counsel for the third party Kam Su Cheun Aurill Counsel for the respondent Liew Min Yi Glenna Counsel for the third party Poon Guokun Nicholas Counsel for the respondent Vikram Nair Counsel for the third party

Parties (5)

Majlis Ugama Islam Singapura Respondent

Arif Rahim Valibhoy Applicant

Imran Amin Valibhoy Third Party

Mohamed Shariff Valibhoy Third Party

Vali Mohamed Shariff Valibhoy Third Party

Case Significance

Arif Rahim Valibhoy v Majlis Ugama Islam Singapura [2023] SGHC 341 was a decision of the General Division of the High Court by Valerie Thean J in Originating Summons No 1168 of 2021 and Summons No 1671 of 2023, heard on 31 August and 16 October 2023 and delivered on 1 December 2023. After the four trustees of the Valibhoy Charitable Trust, administered by MUIS, were removed by orders on 12 June and 12 August 2021, former trustee Arif Rahim Valibhoy obtained leave for judicial review without serving papers on the three other ex-trustees. The judgment addressed their summons for service and to be joined as parties or heard as non-parties, engaging judicial review and joinder in the context of multiple affected trustees.

Summary

This decision arose from judicial review proceedings brought by Mr Arif Rahim Valibhoy, a former trustee of the Valibhoy Charitable Trust, challenging orders by Majlis Ugama Islam Singapura that removed the four trustees. The three other former trustees applied to be served with the papers and to be joined as parties or participate as non-parties. Valerie Thean J joined the three former trustees as respondents and directed them to file a summons and supporting affidavit setting out their position, with costs reserved to the hearing of the originating summons.

What was Arif Rahim Valibhoy v Majlis Ugama Islam Singapura [2023] SGHC 341 about?

It concerned judicial review and joinder after MUIS removed the four trustees of the Valibhoy Charitable Trust in 2021. Valerie Thean J of the General Division of the High Court addressed whether the three other ex-trustees could be served and joined, deciding on 1 December 2023.

Why did the other ex-trustees seek to join the Valibhoy judicial review ([2023] SGHC 341)?

Arif Rahim Valibhoy obtained leave for judicial review of the removal orders without serving papers on the three other former trustees. They filed Summons No 1671 of 2023 to have the papers served and to be joined as parties or to participate as non-parties.

Statutes Cited

Under the Administration of Muslim Law Act (Cap 3) Cases on this Act →

Cases Cited (18)

SLR (12)

[1996] 1 SLR(R) 294 [2006] 1 SLR(R) 112 [2006] 3 SLR(R) 881 [2013] 2 SLR 1108 [2013] 4 SLR 1 [2016] 2 SLR 301 [2018] 1 SLR 894 [2019] 1 SLR 499 [2020] 2 SLR 883 [2021] 2 SLR 1113 [2021] 4 SLR 841 [2022] 2 SLR 280

UK (1)

[1996] 1 WLR 1103

MY (4)

[2001] 6 MLJ 561 [2008] 6 MLJ 488 [2009] 6 MLJ 307 [2017] 8 MLJ 813

HK (1)

[1995] 1 HKC 533