Cheng Tze Tzuen v Dang Lan Anh

[2025] SGHC 112 High Court (General Division) 1 July 2025 • HC/OA 1057/2024 • 29 min read

17 cases cited (13 SG, 4 foreign)

Catchwords

Probate and Administration — Intestate succession Family Law — Void marriage — Whether marriage entered before 1 October 2016 can be void for being a marriage of convenience

Practice Areas

Probate and Administration Family Law

Judges (1)

Valerie Thean Delivered

Counsel (2)

WNLEX LLC Firm Ong Xin Ying Samantha Counsel Claimant

Parties (2)

Cheng Tze Tzuen Claimant Dang Lan Anh Defendant

Case Significance

[2025] SGHC 112 is a High Court (General Division) decision dated 1 July 2025 concerning Family Law and Probate and Administration, specifically addressing intestate succession and void marriage. The judgment was delivered by Valerie Thean. The case was brought by Cheng Tze Tzuen (claimant) against Dang Lan Anh (defendant). Legal representation was provided by WNLEX LLC. The judgment cites 17 cases (13 Singapore, 4 foreign) and references 11 statutory provisions, including the Adoption of Children Act, the Central Provident Fund Act, and the Civil Law Act.

Summary

A son challenged the validity of his deceased father's marriage to a Vietnamese national, seeking a declaration that the marriage was void as a marriage of convenience under s 11A of the Women's Charter to claim a larger share of the estate. The court made no order on the application, finding that s 11A only applies to marriages solemnised on or after 1 October 2016 and the marriage in question was contracted in 2011, and that the claimant should instead pursue statutory procedures at the Family Justice Courts.

What was decided in [2025] SGHC 112?

[2025] SGHC 112 (Cheng Tze Tzuen v Dang Lan Anh) is a High Court (General Division) decision from 1 July 2025 addressing Family Law and Probate and Administration, specifically intestate succession and void marriage. The judgment was delivered by Valerie Thean.

Who were the parties in Cheng Tze Tzuen v Dang Lan Anh?

The claimant in [2025] SGHC 112 was Cheng Tze Tzuen, and the defendant was Dang Lan Anh. Legal representation included WNLEX LLC. The case was decided on 1 July 2025 in the High Court (General Division).

Which judge decided [2025] SGHC 112?

[2025] SGHC 112 was delivered by Valerie Thean in the High Court (General Division) on 1 July 2025. The case concerned Family Law and Probate and Administration.

What cases and statutes does [2025] SGHC 112 cite?

[2025] SGHC 112 cites 17 prior decisions, including 4 from foreign jurisdictions. It references Adoption of Children Act, Central Provident Fund Act, Civil Law Act.

Statutes Cited

Adoption of Children Act (Cap 4)

s 3(1)

Central Provident Fund Act

s 25A

Civil Law Act (Cap 43)

s 27(1)(a)

Family Justice Act

s 22

Immigration Act (Cap 133)

s 57(1)(k) s 57C s 57C(1) s 57C(6)

Interpretation Act (Cap 1)

s 2

Intestate Succession Act

s 7

Prevention of Corruption Act (Cap 241)

s 5

Probate and Administration Act

s 18

Public Trustee Act

s 21

Trustees Act (Cap 337)

s 29

Cases Cited (17)

SG (2)

[2019] SGCA 61 [2025] SGHCF 15

SLR (11)

[1992] 1 SLR(R) 335 [1993] 1 SLR(R) 90 [2009] 3 SLR(R) 957 [2011] 1 SLR 737 [2012] 2 SLR 143 [2016] 5 SLR 693 [2018] 1 SLR 1015 [2019] 3 SLR 874 [2019] 5 SLR 812 [2020] 1 SLR 950 [2025] 3 SLR 16

UK (2)

[1902] 1 Ch 723 [1985] 3 All ER 455

AU (2)

[2013] NSWSC 903 [2016] NSWSC 427

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGHC 112)