XZU v XZV

Facts

A mother applied in SSP 2336 of 2025 for a personal protection order (PPO) on behalf of her daughter, C, who was about 15, against C's paternal grandfather. The grandfather, aged 80, and his wife had lived with the family since C was born and had helped raise the children. The mother and the grandfather's son were going through a divorce, and relations within the household had soured.

The application rested on one incident on 29 October 2025. The grandfather wanted C to finish tidying her study table before she went out with a friend; he raised his voice, told her to leave the house, and then asked why she had come back. C retorted that the house was not his. The mother later added an incident on 26 November 2025 in which, she said, the grandfather slammed his cup down and stared at C over lunch. He explained that his hands were weak and that he sometimes put things down heavily. C gave evidence, and it was common ground that he had never been physically violent to her.

Issues

1. Whether the grandfather's conduct amounted to emotional or psychological abuse, and so family violence, under the Women's Charter 1961 as amended in 2025.
2. Whether a protection order was necessary for C's protection or personal safety.

Holding

The District Judge dismissed the application because neither requirement for a PPO was met: there was no family violence and no need for an order. The mother was ordered to pay the grandfather's costs, as the application was largely misconceived, although it was not brought for any improper purpose.

Reasoning

The court preferred C's account of the October incident to the grandfather's, whose evidence at trial contradicted his own affidavit. Even so, the conduct did not reach the legal threshold. Following XWB v XWC [2025] SGFC 135, the court held that emotional or psychological abuse requires demonstrable harm to the victim, beyond the frustration and unhappiness that are part of everyday family life. Breaching a PPO is a criminal offence, and the statutory definition and examples focus on the harm caused, which supports a high bar.

Here the grandfather was disciplining C, as she herself accepted; he used no abusive language, and his words were at most angry. The November incident did not involve him engaging C directly, and C did not say he stared at her in a threatening way. There was no medical or other objective evidence of harm, and C was later seen at ease at home and said goodbye to him before a trip. The mother, not C, had decided to apply after doing her own research.

Necessity failed as well. A protection order is not meant to punish, and the court must judge the risk of future violence; in 14 years living together there had been no proven violence. The judge encouraged the family to consider counselling to repair the relationship.

From the judgment