JENNY PRAWESTI v SAUW TJIAUW KOE

[2025] SGHC 209 High Court (General Division) 23 October 2025 • HC/S 375/2022 • 67 min read
17 cases cited (14 SG, 3 foreign)

Catchwords

Trusts — Express trusts — Certainties — Whether a letter of indemnity sufficiently identifies the subject matter of the purported trust Trusts — Express trusts — Certainties — Whether a letter of indemnity sufficiently evinces a putative settlor’s intention to create a trust Trusts — Resulting trusts — Sole financial responsibility for 25 of the properties fell on the mother — Whether there was a resulting trust in the mother’s favour Trusts — Constructive trusts — Common intention constructive trusts — Daughter alleged that her mother made an oral representation over 20 years ago that they would purchase properties together as equal owners in the future, while the mother alleged that she had always told the daughter that she was only borrowing the daughter’s name for the properties — Whether there was a common intention for either party to hold their various legal interests in the 26 properties on trust for the other

Practice Areas

Trusts

Judges (1)

Hri Kumar Nair Delivered

Parties (2)

Jenny Prawesti Plaintiff Sauw Tjiauw Koe Defendant

Case Significance

[2025] SGHC 209 is a High Court (General Division) decision dated 23 October 2025 concerning Trusts, specifically addressing express trusts, resulting trusts, and constructive trusts. The judgment was delivered by Hri Kumar Nair. The case was brought by Jenny Prawesti (plaintiff) against Sauw Tjiauw Koe (defendant). The judgment cites 17 cases (14 Singapore, 3 foreign) and references 2 statutory provisions, including the Civil Law Act and the Conveyancing and Law of Property Act.

Summary

A daughter claimed 50% beneficial interest in 26 Singapore properties purchased between 2002 and 2012, while her mother counterclaimed that the daughter's registered interests were held on trust for her. The court found a resulting trust in the mother's favour for 25 properties where the mother bore sole financial responsibility, and dismissed the daughter's claim of a common intention constructive trust based on an alleged oral representation made over 20 years ago.

What was decided in [2025] SGHC 209?

[2025] SGHC 209 (JENNY PRAWESTI v SAUW TJIAUW KOE) is a High Court (General Division) decision from 23 October 2025 addressing Trusts, specifically express trusts, resulting trusts, and constructive trusts. The judgment was delivered by Hri Kumar Nair.

Who were the parties in JENNY PRAWESTI v SAUW TJIAUW KOE?

The plaintiff in [2025] SGHC 209 was Jenny Prawesti, and the defendant was Sauw Tjiauw Koe. The case was decided on 23 October 2025 in the High Court (General Division).

Which judge decided [2025] SGHC 209?

[2025] SGHC 209 was delivered by Hri Kumar Nair in the High Court (General Division) on 23 October 2025. The case concerned Trusts.

What cases and statutes does [2025] SGHC 209 cite?

[2025] SGHC 209 cites 17 prior decisions, including 3 from foreign jurisdictions. It references Civil Law Act, Conveyancing and Law of Property Act.

Statutes Cited

Civil Law Act (Cap 43)
s 7
Conveyancing and Law of Property Act (Cap 61)
s 73A

Cases Cited (17)

SG (5)
[2016] SGHC 225 [2023] SGHC 47 [2024] SGHC(A) 27 [2025] SGHC 119 [2025] SGHC 145
SLR (9)
[2014] 3 SLR 1048 [2015] 1 SLR 1097 [2016] 3 SLR 1222 [2019] 1 SLR 908 [2020] 5 SLR 1298 [2022] 2 SLR 457 [2022] 5 SLR 451 [2023] 5 SLR 1125 [2025] 1 SLR 758
UK (3)
[1991] 1 AC 107 [2008] EWCA Civ 347 [2010] EWHC 1920

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGHC 209)