LAKSHMI ANIL SALGAOCAR suing as the Administratrix of the ESTATE OF ANIL VASSUDEVA SALGAOCAR deceased v PURNIMA ANIL SALGAOCAR

[2023] SGHC 49 High Court (General Division) 28 February 2023 HC/OC 49/2022 ( HC/SUM 2031/2022 ) 13 min read

5 cases cited (4 SG, 1 foreign) Cited by 2 cases

Key facts

Court	High Court (General Division)
Decided	28 February 2023
Judge	Lai Siu Chiu
Charges / claim	Contract, Civil Procedure
Counsel	Drew & Napier LLC, Niru & Co LLC, Estad Amber Joy, Liew Teck Huat, Lim Gerui, Melinna Teo, Niru Pillai, Phang Cun Kuang

Source: [2023] SGHC 49, High Court (General Division), decided 28 February 2023 — eLitigation. Updated 10 July 2026.

Catchwords

Contract — Contractual terms — Rules of construction Civil Procedure — Injunctions — Enforcement of negative covenant

Practice Areas

Contract Civil Procedure

Judges (1)

Lai Siu Chiu Delivered

Counsel (8)

Drew & Napier LLC Firm Niru & Co LLC Firm Estad Amber Joy Counsel Defendant Liew Teck Huat Counsel Claimant Lim Gerui Counsel Defendant Melinna Teo Counsel Defendant Niru Pillai Counsel Claimant Phang Cun Kuang Counsel Claimant

Parties (2)

Lakshmi Anil Salgaocar (suing as the administratrix of the estate of Anil Vassudeva Salgaocar, deceased) Claimant Purnima Anil Salgaocar Defendant

Case Significance

Lakshmi Anil Salgaocar (suing as administratrix of the estate of Anil Vassudeva Salgaocar, deceased) v Purnima Anil Salgaocar [2023] SGHC 49 sets out the grounds of decision of Lai Siu Chiu SJ in the General Division of the High Court, in Originating Claim No 49 of 2022 (Summons No 2031 of 2022), heard on 28 June 2022 and dated 28 February 2023. The dispute was between the claimant mother and the defendant daughter over the mother's administration of the estate; the parties had entered a settlement agreement restricting either from bringing proceedings against the other until a separate estate action was resolved. When the daughter initiated separate probate proceedings, the claimant sought an interim injunction to enforce that negative covenant. The question was whether the claimant's alleged but unproven breaches meant the negative covenant was not binding and could not ground an interim injunction, engaging contractual construction principles.

[2023] SGHC 49 explained

LAKSHMI ANIL SALGAOCAR suing as the Administratrix of the ESTATE OF ANIL VASSUDEVA SALGAOCAR deceased v PURNIMA ANIL SALGAOCAR ([2023] SGHC 49) is a Singapore judgment decided by the High Court (General Division) on 28 February 2023. It is categorised under Contract 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 49 about?

LAKSHMI ANIL SALGAOCAR suing as the Administratrix of the ESTATE OF ANIL VASSUDEVA SALGAOCAR deceased v PURNIMA ANIL SALGAOCAR ([2023] SGHC 49) is a High Court (General Division) decision from 2023. Its published catchwords are “Contract — Contractual terms — Rules of construction” and “Civil Procedure — Injunctions — Enforcement of negative covenant”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.

How influential is [2023] SGHC 49?

Within this corpus, [2023] SGHC 49 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

This dispute was between Lakshmi Anil Salgaocar, suing as administratrix of her late husband's estate, and her daughter Purnima Anil Salgaocar, an estate beneficiary, over a settlement agreement that restricted either party from bringing proceedings until a separate action was resolved. When the daughter commenced separate probate proceedings, the mother sought an interim injunction to enforce the negative covenant. Lai Siu Chiu SJ held that even if the mother had breached the agreement the appropriate course was to sue on it, found the daughter's proceedings a breach of the covenant, and granted the interim injunction.

What was Lakshmi Anil Salgaocar v Purnima Anil Salgaocar [2023] SGHC 49 about?

The claimant mother sought an interim injunction to hold the defendant daughter to a negative covenant in a settlement agreement barring proceedings until a separate estate action was resolved, after the daughter began separate probate proceedings. Lai Siu Chiu SJ heard the matter.

What was the key question in Lakshmi Anil Salgaocar v Purnima Anil Salgaocar ([2023] SGHC 49)?

The question was whether the claimant's alleged but unproven breaches of the settlement agreement meant its negative covenant was not binding on the defendant and so could not serve as the basis for an interim injunction against her, engaging contractual construction principles.