WRX v WRY

Case Significance

WRX v WRY and another matter [2024] SGHC(A) 22 was a single judgment delivered on 29 July 2024 (reserved after hearings on 15 May and 3 June 2024) by the Appellate Division of the High Court, comprising Woo Bih Li JAD, Debbie Ong Siew Ling JAD and Philip Jeyaretnam J, with Debbie Ong Siew Ling JAD delivering the judgment of the court. The matter concerned AD/CA 132/2023, an appeal by the husband against a Family Division judge's decision on ancillary matters in WRX v WRY [2023] SGHCF 50, together with AD/SUM 13/2024, the husband's application to adduce further evidence. The catchwords cover Family Law — Maintenance (wife and child) and Matrimonial assets — Division — Adverse inference drawn for non-disclosure.

The judgment stated that it principally concerned how a court should give effect to an adverse inference drawn against a party who breached the duty to provide full and frank disclosure of assets and means in ancillary matters proceedings following a divorce. The court held that undisclosed assets notionally restored to the matrimonial pool to give effect to an adverse inference against the non-disclosing party should not ordinarily be counted as part of that party's direct contributions to the acquisition of matrimonial assets. The judgment noted the husband was a French citizen and Singapore Permanent Resident, and recorded that the wife did not appeal. The appellant was represented by counsel from Engelin Teh Practice LLC including Chee Ying Li Cherilynn and Chloe Chua Kay Ee, and the respondent by Alfred Dodwell of Dodwell & Co LLC.