YCD v YCE

Case Significance

Assistant Registrar Jasmine Loo of the Family Court delivered this grounds of decision on 23 April 2026, following hearings on 9 and 26 March 2026. The case raised novel questions in a striking-out application (FC/SUM 2950/2025) by the alleged biological father (applicant YCD) against a mother's application (FC/OAG 154/2025) seeking maintenance. The mother had divorced her husband and obtained a child maintenance order, then later sought maintenance from YCD, whom she alleged was the biological father of the child. Her application sought $8,926 in monthly maintenance or a lump sum of $1,071,120 under the Guardianship of Infants Act 1934 (2020 Rev Ed).

The decision addressed three novel questions: first, whether the court had power to order the parties to undergo paternity testing; second, whether the extended doctrine of res judicata barred the mother from seeking maintenance from an alleged biological father after maintenance had already been ordered against her former husband; and third, whether the principle against double recovery applied. The Guardianship of Infants Act and Evidence Act were both engaged. Urmi Nag and Clement Yap Ying Jie of Harry Elias Partnership LLP acted for the applicant; Diana Foo of Legal Eagles acted for the respondent mother.