SALMIZAN BIN ABDULLAH v CRAPPER IAN ANTHONY
Key facts
| Court | High Court (General Division) |
|---|---|
| Decided | |
| Judge | Goh Yihan |
| Charges / claim | Damages, Tort |
| Counsel | Providence Law Asia LLC, Tan Chin Hoe & Co, Tommy Choo, Mark Go LLC, Leo Zhi Wei, Ling Leong Hui, Siew Jey Ren, Tan Seng Chew Richard |
Source: [2023] SGHC 75, High Court (General Division), decided — eLitigation. Updated .
Catchwords
Practice Areas
Judges (1)
Counsel (7)
Case Significance
Salmizan bin Abdullah v Crapper, Ian Anthony [2023] SGHC 75 was decided by Goh Yihan JC in the General Division of the High Court, Suit No 377 of 2022 (Summons No 3827 of 2022), heard on 12 January 2023 with judgment reserved and delivered on 30 March 2023. The defendant applied under O 33 r 2 of the Rules of Court 2014 for the preliminary determination of three questions of law on whether causation could be reserved to the assessment of damages stage in a negligence claim, and on how different types of damage relate to the cause of action. The court had the assistance of young independent counsel Ms Leo Zhi Wei.
[2023] SGHC 75 explained
SALMIZAN BIN ABDULLAH v CRAPPER IAN ANTHONY ([2023] SGHC 75) is a Singapore judgment decided by the High Court (General Division) on 30 March 2023. It is categorised under Damages and Tort. Within this corpus it has since been cited by 6 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 75 about?
SALMIZAN BIN ABDULLAH v CRAPPER IAN ANTHONY ([2023] SGHC 75) is a High Court (General Division) decision from 2023. Its published catchwords are “Damages — Assessment”, “Tort — Negligence — Causation — Whether causation may be disputed at the assessment of damages hearing”, “Tort — Negligence — Damages — What makes out the elements of negligence to entitle a claimant to damages”, and “Tort — Negligence — Breach of duty — Whether different types of damage give rise to different causes of action for the same breach of duty”, 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 75 consider?
The judgment refers to Civil Law Act (Cap 43) and State Courts Act (Cap 321). The statutes cited are listed in full on this page, each linking to its primary text.
How influential is [2023] SGHC 75?
Within this corpus, [2023] SGHC 75 has been cited by 6 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 a personal injury motor accident claim, the defendant applied for the preliminary determination of questions of law on whether, and to what extent, causation could be reserved to the assessment of damages stage. The court answered that causation cannot be reserved in whole to that stage, and answered a reframed version of the further questions in the negative with qualifications. It held that once interlocutory judgment established liability the defendant could not challenge it, though issues about the extent of proven damage remained for the assessment stage.
What was Salmizan bin Abdullah v Crapper, Ian Anthony [2023] SGHC 75 about?
The defendant applied under O 33 r 2 of the Rules of Court 2014 for preliminary determination of three questions of law on whether causation in a negligence claim can be reserved to the assessment of damages stage. Goh Yihan JC heard the application on 12 January 2023.
What questions of law were raised in Salmizan bin Abdullah v Crapper ([2023] SGHC 75)?
The three questions asked whether causation can be reserved in toto to the assessment of damages stage, and if not, whether it can be reserved where parties accept the claimant suffered special damages, or general damages, causally connected to the defendant's breach of duty.
Statutes Cited
Cases Cited (49)
Cited By (6)
Related cases
Other Singapore judgments involving the same parties or counsel.
Referenced in
Statutes interpreted in this judgment
Legal concepts & references
Judgment
Read the full judgment on the official Singapore Courts portal.
Read on eLitigationSource: eLitigation ([2023] SGHC 75)