XPX v XPW
Key facts
| Court | Family Court |
|---|---|
| Decided | |
| Judge | Kow Keng Siong |
| Charges / claim | Costs |
| Counsel | Advocatus Law LLP, Phoenix Law Corporation, Eileen Yeo, Ganga d/o Avadiar, Michelle Lynn Fernandez, Sofia Bakhash |
Source: [2026] SGFC 52, Family Court, decided — eLitigation. Updated .
Catchwords
Practice Areas
Judges (1)
Counsel (6)
Parties (2)
Case Significance
XPX v XPW [2026] SGFC 52, decided on 8 April 2026 by District Judge Kow Keng Siong in the Family Court, addressed the costs consequences of legal aid in family proceedings. The Mother (XPX) had successfully obtained protective orders on behalf of the Daughter against the Father (XPW) in SSP 442/2025. She then sought costs, but the Father held a Grant of Aid from the Legal Aid Bureau, engaging s 12(4)(c) of the Legal Aid and Advice Act 1995, which ordinarily shields an aided person from costs. The judgment examines when the s 14(3) exceptions apply — namely, where the Grant of Aid was obtained by fraud or misrepresentation, or where the aided person acted improperly — and also considers whether an aided person is protected from costs incurred before the Grant of Aid was filed.
[2026] SGFC 52 explained
XPX v XPW ([2026] SGFC 52) is a Singapore judgment decided by the Family Court on 8 April 2026. It is categorised under Costs. 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 [2026] SGFC 52 about?
XPX v XPW ([2026] SGFC 52) is a Family Court decision from 2026. Its published catchwords are “Costs – Legal aid – Whether aided person liable for costs for fraud, misrepresentation, or improper conduct – Relevant considerations – Section 14(3) Legal Aid and Advice Act 1995 Costs – Legal aid – Whether aided person protected from costs incurred before Grant of Aid was filed – Section 12(4)(c) Legal Aid and Advice Act 1995”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.
Which legislation does [2026] SGFC 52 consider?
The judgment refers to Evidence Act (Cap 97) and Legal Aid and Advice Act. The statutes cited are listed in full on this page, each linking to its primary text.
Summary
Following a successful six-day trial in which the Mother obtained protective orders for her daughter against the Father (XPX v XPW [2026] SGFC 30), the Mother sought costs of $85,000 against the Father, who held a Legal Aid Bureau Grant of Aid under the Legal Aid and Advice Act 1995. The issues were whether the Father's grant had been obtained by fraud or misrepresentation, or whether he had acted improperly under s 14(3), so as to lose the costs immunity conferred by s 12(4)(c), and whether costs incurred before the Grant of Aid was filed remained recoverable. District Judge Kow Keng Siong found no fraud or improper conduct sufficient to displace s 12(4)(c) protection, but ordered the Father to pay $20,000 representing costs incurred before the Grant of Aid was filed, as that earlier period fell outside the statutory protection.
When can an aided person be ordered to pay costs despite a Legal Aid Bureau Grant of Aid in Singapore ([2026] SGFC 52)?
Under s 14(3) of the Legal Aid and Advice Act 1995, examined in XPX v XPW [2026] SGFC 52, an aided person may be ordered to pay costs where the Grant of Aid was obtained by fraud or misrepresentation, or the aided person acted improperly in the proceedings.
Statutes Cited
Cases Cited (22)
Related cases
Other Singapore judgments involving the same parties or counsel.
Referenced in
Statutes interpreted in this judgment
Judgment
Read the full judgment on the official Singapore Courts portal.
Read on eLitigationSource: eLitigation ([2026] SGFC 52)