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)

Key facts

Court High Court (General Division)
Decided
Judge Hri Kumar Nair
Charges / claim Trusts

Source: [2025] SGHC 209, High Court (General Division), decided — eLitigation. Updated .

Catchwords

Practice Areas

Judges (1)

Parties (2)

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.

[2025] SGHC 209 explained

JENNY PRAWESTI v SAUW TJIAUW KOE ([2025] SGHC 209) is a Singapore judgment decided by the High Court (General Division) on 23 October 2025. It is categorised under Trusts. It is a recent decision; within this corpus no later judgment has cited it yet. 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] SGHC 209 about?

JENNY PRAWESTI v SAUW TJIAUW KOE ([2025] SGHC 209) is a High Court (General Division) decision from 2025. Its published catchwords are “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”, and “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”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.

Which legislation does [2025] SGHC 209 consider?

The judgment refers to Civil Law Act (Cap 43) and Conveyancing and Law of Property Act (Cap 61). The statutes cited are listed in full on this page, each linking to its primary text.

What earlier Singapore cases does [2025] SGHC 209 cite?

Among the in-corpus authorities it refers to are [2025] SGHC 145, [2025] SGHC 119, and [2024] SGHC(A) 27. The complete list of cases cited, and of later cases that cite this decision, is shown on this page.

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 ([2025] SGHC 209)?

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

Cases Cited (17)

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

Referenced in

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGHC 209)