DDN v DDO

[2024] SGHC(A) 2 High Court (Appellate Division) 17 January 2024 • AD/CA 98/2023 • 18 min read
6 cases cited Cited by 2 cases

Catchwords

Practice Areas

Judges (2)

Counsel (3)

Parties (2)

Case Significance

DDN v DDO [2024] SGHC(A) 2 was decided in the Appellate Division of the High Court of Singapore in Civil Appeal No 98 of 2023, with Debbie Ong Siew Ling JAD delivering the judgment of the court (sitting with Audrey Lim J) on 17 January 2024 after a hearing on 9 November 2023. The appeal arose from a Judge of the Family Division varying the parties' by-consent access orders, in FC/SUM 1745/2023, due to a material change in circumstances. The judgment refers to the appellant as the Father, a doctor, and the respondent as the Mother, a teacher; the parties married in 2006 and have two children, a daughter aged 15 and a son aged 12.

Only the Father filed submissions for the appeal. The court dismissed AD 98 in its entirety, while elaborating on the applicable legal principles for varying access orders on the basis of a material change in circumstances and on how the notion of "Therapeutic Justice" applies in that context. The Mother had commenced divorce proceedings on 1 June 2021.

[2024] SGHC(A) 2 explained

DDN v DDO ([2024] SGHC(A) 2) is a Singapore judgment decided by the High Court (Appellate Division) on 17 January 2024. It is categorised under Family Law. 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 [2024] SGHC(A) 2 about?

DDN v DDO ([2024] SGHC(A) 2) is a High Court (Appellate Division) decision from 2024. Its published catchwords are “Family Law — Custody — Access — Variation — Therapeutic justice” and “Family Law — Custody — Access — Variation — Material change in circumstances”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.

How influential is [2024] SGHC(A) 2?

Within this corpus, [2024] SGHC(A) 2 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

In this appeal referred to as concerning the Father and the Mother, the father appealed against a Family Division judge's decision to vary the parties' by-consent access orders to their two children on the basis of a material change in circumstances. The Appellate Division of the High Court considered the applicable principles for varying access orders on a material change in circumstances and how the notion of Therapeutic Justice applied in the context. The court found the reduced access arrangements were not unreasonable, dismissed the appeal in its entirety, and made no order as to costs given that the mother was unrepresented and had not filed submissions.

What did the court decide in DDN v DDO [2024] SGHC(A) 2?

The Appellate Division of the High Court dismissed the Father's appeal in its entirety, upholding the variation of by-consent access orders made due to a material change in circumstances. Debbie Ong Siew Ling JAD delivered the judgment, sitting with Audrey Lim J, on 17 January 2024.

What principles did [2024] SGHC(A) 2 address on varying access orders?

The court elaborated on the legal principles for varying access orders on the basis of a material change in circumstances, and explained how the notion of "Therapeutic Justice" applies in that context, in an appeal concerning by-consent access orders for two children.

Cases Cited (6)

SG (2)
[2016] SGHCF 1 [2023] SGHCF 3
SLR (4)
[2018] 2 SLR 833 [2018] 5 SLR 1089 [2021] 5 SLR 1233 [2022] 4 SLR 1181

Cited By (2)

Referenced in

Legal concepts & references

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2024] SGHC(A) 2)