LE NINH TIEN v RAINBOW FOREST ENTERPRISES LIMITED & 5 Ors

[2025] SGHC 240 High Court (General Division) 4 December 2025 • HC/OC 665/2024 ( HC/RA 118/2025 ) • 29 min read

17 cases cited (15 SG, 2 foreign)

Catchwords

Conflict of Laws — Natural forum

Practice Areas

Conflict of Laws

Judges (1)

Aidan Xu @ Aedit Abdullah Delivered

Counsel (8)

Titanium Law Chambers LLC Firm Tito Isaac & Co LLP Firm Alexius Chew Hui Jun Counsel Appellant Francis Chan Wei Wen Counsel Appellant Isaac Tito Shane Counsel Respondent Jaspreet Kaur Purba Counsel Respondent Kenneth Loh Ding Chao Counsel Appellant Tan Youliang Counsel Respondent

Parties (7)

Rainbow Forest Enterprises Limited Defendant Song Doc MV19 Pte Ltd Defendant Gordon Roy Bate Defendant Le Ninh Tien Plaintiff Lu Qianxiang Defendant Stevean Goh Hwee Peng Defendant Truong Dinh Hoe Defendant

Case Significance

[2025] SGHC 240 is a High Court (General Division) decision dated 4 December 2025 concerning Conflict of Laws, specifically addressing natural forum. The judgment was delivered by Aidan Xu @ Aedit Abdullah. The case was brought by Le Ninh Tien (plaintiff) against Rainbow Forest Enterprises Limited and others (defendant). Legal representation was provided by Titanium Law Chambers LLC and Tito Isaac & Co LLP. The judgment cites 17 cases (15 Singapore, 2 foreign) and references 1 statutory provision, namely the Companies Act.

Summary

In a minority oppression claim involving a Singapore-incorporated vessel-holding company, the defendant sought a stay of the counterclaim on grounds of forum non conveniens, arguing Vietnam or Cambodia were more appropriate forums. The court dismissed the appeal against the refusal to stay, finding the defendant had not demonstrated that any foreign forum was distinctly more appropriate than Singapore, with overlapping proceedings pointing somewhat towards Singapore.

What was decided in [2025] SGHC 240?

[2025] SGHC 240 (LE NINH TIEN v RAINBOW FOREST ENTERPRISES LIMITED & 5 Ors) is a High Court (General Division) decision from 4 December 2025 addressing Conflict of Laws, specifically natural forum. The judgment was delivered by Aidan Xu @ Aedit Abdullah.

Who were the parties in LE NINH TIEN v RAINBOW FOREST ENTERPRISES LIMITED & 5 Ors?

The plaintiff in [2025] SGHC 240 was Le Ninh Tien, and the defendant was Rainbow Forest Enterprises Limited, Song Doc MV19 Pte Ltd. Legal representation included Titanium Law Chambers LLC and Tito Isaac & Co LLP. The case was decided on 4 December 2025 in the High Court (General Division).

Which judge decided [2025] SGHC 240?

[2025] SGHC 240 was delivered by Aidan Xu @ Aedit Abdullah in the High Court (General Division) on 4 December 2025. The case concerned Conflict of Laws.

What cases and statutes does [2025] SGHC 240 cite?

[2025] SGHC 240 cites 17 prior decisions, including 2 from foreign jurisdictions. It references Companies Act.

Statutes Cited

Companies Act (Cap 50)

s 216

Cases Cited (17)

SG (1)

[2025] SGHCR 23

SLR (14)

[2007] 1 SLR(R) 377 [2008] 4 SLR(R) 543 [2010] 3 SLR 1007 [2011] 1 SLR 391 [2013] 4 SLR 718 [2017] 2 SLR 265 [2017] 2 SLR 814 [2018] 3 SLR 423 [2019] 2 SLR 372 [2020] 2 SLR 221 [2020] 2 SLR 638 [2022] 1 SLR(R) 880 [2023] 3 SLR 1092 [2024] 3 SLR 476

UK (2)

[1987] AC 460 [2004] EWHC 2659

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGHC 240)