NATIXIS, SINGAPORE BRANCH v SESHADRI RAJAGOPALAN & 2 Ors

[2025] SGCA 29 Court of Appeal 24 June 2025 CA/CA 39/2024 · CA/CA 40/2024 · CA/CA 41/2024 109 min read
66 cases cited (45 SG, 21 foreign) Cited by 1 case

Outcome

Appeal dismissed

we dismiss the appeals.

Source: [2025] SGCA 29, Court of Appeal, decided 24 June 2025. Read directly from the judgment.

Key facts

Court Court of Appeal
Decided
Judges Kannan Ramesh, Steven Chong, Sundaresh Menon
Charges / claim Admiralty and Shipping, Insolvency Law
Outcome Appeal dismissed
Counsel Collin Seah Law Practice, JFN Chambers LLC, Joseph Tan Jude Benny LLP, Resource Law LLC, Shook Lin & Bok LLP, TSMP Law Corporation, Choi Yee Hang Ian, Chua Li-Ann Nicolette, Isaac Tay Zhuo Yan, Jonathan Lim Shi Cao, Lee Chong Jie, Lee Koon Foong Adam Hariz, Lin Weiwen Moses, Ng Jern-Fei, Ryan Mark Lopez, Seah Lee Guan Collin, Sonia Elizabeth Rajendra, Soong Jun De, Sze Kian Chuan, Tessa Lim Yong Rong, Thio Shen Yi

Source: [2025] SGCA 29, Court of Appeal, decided — eLitigation. Updated .

Catchwords

Practice Areas

Judges (3)

Counsel (21)

Parties (6)

Case Significance

[2025] SGCA 29 is a Court of Appeal decision dated 24 June 2025 concerning Admiralty and Shipping and Insolvency Law, specifically addressing admiralty jurisdiction and arrest and administration of insolvent estates. The judgment was delivered by Steven Chong, with Kannan Ramesh and Sundaresh Menon on the coram. The case was brought by Natixis, Singapore Branch and others (appellant) against Nan Chiau Maritime (Pte) Ltd (Judicial Managers Appointed) and others (respondent). Legal representation was provided by Collin Seah Law Practice and Joseph Tan Jude Benny LLP. The judgment cites 66 cases (45 Singapore, 21 foreign) and references 4 statutory provisions, including the Companies Act, the Insolvency, and the Restructuring and Dissolution Act.

[2025] SGCA 29 explained

NATIXIS, SINGAPORE BRANCH v SESHADRI RAJAGOPALAN & 2 Ors ([2025] SGCA 29) is a Singapore judgment decided by the Court of Appeal on 24 June 2025. It is categorised under Admiralty and Shipping and Insolvency Law. Within this corpus it has since been cited by 1 other reported Singapore judgment, 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 [2025] SGCA 29 about?

NATIXIS, SINGAPORE BRANCH v SESHADRI RAJAGOPALAN & 2 Ors ([2025] SGCA 29) is a Court of Appeal decision from 2025. Its published catchwords are “Admiralty and Shipping — Admiralty jurisdiction and arrest — Action in rem — Statutory liens”, “Insolvency Law — Administration of insolvent estates — Judicial management — Ex parte James principle”, and “Insolvency Law — Administration of insolvent estates — Judicial management — Disposal of charged property — Section 100(2) Insolvency, Restructuring and Dissolution Act 2018 (2020 Rev Ed)”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.

Which legislation does [2025] SGCA 29 consider?

The judgment refers to Companies Act (Cap 50), Insolvency, Restructuring and Dissolution Act, Restructuring and Dissolution Act, and Supreme Court of Judicature Act (Cap 322). The statutes cited are listed in full on this page, each linking to its primary text.

What earlier Singapore cases does [2025] SGCA 29 cite?

Among the in-corpus authorities it refers to are [2024] SGHC 113. The complete list of cases cited, and of later cases that cite this decision, is shown on this page.

How influential is [2025] SGCA 29?

Within this corpus, [2025] SGCA 29 has been cited by 1 later reported Singapore judgment. 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

Three banks — Natixis, Société Générale and HSBC — appealed against the dismissal of their claims to the sale proceeds of a vessel owned by Nan Chiau Maritime, a company in judicial management related to the collapsed Hin Leong Trading group. The banks argued they held statutory liens through writs in rem issued against the vessel, which the judicial managers had arranged to be sold by a Gibraltar court. The Court of Appeal dismissed all three appeals, holding the judicial sale did not constitute a disposal by the judicial managers and the banks' writs in rem did not give them security interests in the vessel.

What was decided in [2025] SGCA 29?

[2025] SGCA 29 (NATIXIS, SINGAPORE BRANCH v SESHADRI RAJAGOPALAN & 2 Ors) is a Court of Appeal decision from 24 June 2025 addressing Admiralty and Shipping and Insolvency Law, specifically admiralty jurisdiction and arrest and administration of insolvent estates. The judgment was delivered by Steven Chong.

Who were the parties in NATIXIS, SINGAPORE BRANCH v SESHADRI RAJAGOPALAN & 2 Ors ([2025] SGCA 29)?

The appellant in [2025] SGCA 29 was Natixis, Singapore Branch, Societe Generale, Singapore Branch, and the respondent was Nan Chiau Maritime (Pte) Ltd (Judicial Managers Appointed), Paresh Tribhovan Jotangia. Legal representation included JFN Chambers LLC and Collin Seah Law Practice. The case was decided on 24 June 2025 in the Court of Appeal.

Which judge decided [2025] SGCA 29?

[2025] SGCA 29 was delivered by Steven Chong in the Court of Appeal on 24 June 2025. Kannan Ramesh and Sundaresh Menon also sat on the coram. The case concerned Admiralty and Shipping and Insolvency Law.

What cases and statutes does [2025] SGCA 29 cite?

[2025] SGCA 29 cites 66 prior decisions, including 21 from foreign jurisdictions. It references Companies Act, Insolvency, Restructuring and Dissolution Act.

Statutes Cited

Cases Cited (66)

SLR (44)
[1991] 2 SLR(R) 643 [1993] 2 SLR(R) 136 [1993] 3 SLR(R) 894 [1994] 3 SLR(R) 574 [1998] 2 SLR(R) 630 [1999] 2 SLR(R) 793 [2000] 2 SLR(R) 399 [2001] 2 SLR(R) 180 [2002] 1 SLR(R) 418 [2002] 2 SLR(R) 789 [2003] 3 SLR(R) 362 [2004] 1 SLR(R) 671 [2006] 1 SLR(R) 484 [2008] 4 SLR(R) 994 [2009] 4 SLR(R) 525 [2011] 1 SLR 391 [2011] 3 SLR 487 [2013] 4 SLR 615 [2014] 1 SLR 1389 [2014] 1 SLR 733 [2014] 2 SLR 815 [2016] 1 SLR 448 [2017] 2 SLR 592 [2017] 2 SLR 850 [2018] 2 SLR 129 [2018] 5 SLR 125 [2018] 5 SLR 1358 [2019] 1 SLR 680 [2020] 2 SLR 1332 [2021] 1 SLR 998 [2021] 2 SLR 1141 [2021] 4 SLR 526 [2022] 2 SLR 1385 [2023] 2 SLR 389 [2023] 5 SLR 513 [2024] 1 SLR 1054 [2024] 1 SLR 266 [2024] 2 SLR 790 [2024] 4 SLR 896 [2024] 5 SLR 1006 [2024] 5 SLR 138 [2025] 1 SLR 432 [2025] 1 SLR 492 [2025] 3 SLR 868
UK (16)
[1901] AC 495 [1907] 1 KB 865 [1924] 1 KB 431 [1980] Ch 196 [1988] 1 Ch 275 [1999] 2 AC 349 [2002] 1 AC 336 [2007] 2 AC 85 [2018] 1 WLR 1564 [2021] Ch 1 [2021] EWHC 310 [2021] QB 129 [2024] 1 WLR 541 [2024] 3 WLR 659 [2025] 1 WLR 810 [2025] AC 555
AU (3)
[2017] WASC 152 [2024] NSWCA 284 [2024] NSWCA 301
MY (2)
[2021] 9 MLJ 936 [2023] 12 MLJ 53

Cited By (1)

Related cases

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Referenced in

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGCA 29)