VMG v VMH

Facts

The father (the appellant, acting in person) appealed against a District Judge's dismissal of his application in FC/SUM 1644/2024, which had left sole care and control of the son with the mother. The appeal was District Court Appeal No 101 of 2024, heard with Summons 180 of 2025 in the General Division of the High Court (Family Division).

He asked for care and control to be reversed, for disclosure of the mother's income and her mother's passport details, for the child interview records, for social support orders, for a new judge, and for the mother to undergo a mental health assessment. At his request the court had ordered both parents to be assessed; the mother complied and her Institute of Mental Health report showed no mental illness, while the father did not attend, saying he had no psychiatric issues.

Issues

1. Whether the mother should be ordered to undergo a mental health assessment.
2. Whether care and control of the child should be transferred to the father, with disclosure of the mother's income and her mother's passport details.
3. Whether there was any basis for disclosure of the child interview records, social support orders, or a change of judge.
4. Whether the father's further summons should be granted.

Holding

The court dismissed the appeal in its entirety and also dismissed HCF/SUM 180/2025. Care and control remained with the mother. The court noted that the existing access orders stay in force until new orders are made and that the mother must comply with them.

Reasoning

The court rescinded its assessment order at the 7 May 2025 hearing because the father appeared unwilling to be assessed, and the mother's report left nothing further to order.

On care and control, the father offered no evidence that the mother had psychiatric issues. Her retrenchment was due to a business slowdown, not her ability or attitude, and her ad hoc work still earned a living wage. Her explanation that she took leave or used daycare when her parents went to India had been accepted below and was unchallenged. Care and control staying with her was in the child's best interests, and no further disclosure was needed.

On the remaining requests, there was no legal basis to disclose child interview records, given the confidentiality stressed in WKM v WKN [2024] SGCA 1, nor for social support orders. The father did not say clearly which judge he objected to, and the same judge having heard two of his earlier appeals was no reason to step aside. The summons sought substantially the same relief and fell with the appeal.

From the judgment