VPN v VPO

Facts

The parents in FC/D 3584/2019 had a consent order dated 6 March 2020 for their son, born in 2018, giving them joint custody with care and control to the mother, regular access to the father, and requiring the father to pay 65% of the child's expenses. The order had been varied twice before, in VPN v VPO [2021] SGFC 20 and VPN v VPO [2022] SGFC 15, and on appeal the High Court ordered school holidays to be shared equally. The father had also brought a committal application alleging 22 breaches; the court found only one, the mother's enrolment of the child in a preschool without consulting him, fined her $150 and ordered him to pay her $4,500 in costs.

Three variation applications were heard together. In FC/SUM 1680 of 2024 the father sought to reduce his share of maintenance. In FC/SUM 2583 of 2024 the mother sought to vary access and obtain sole authority over education. In FC/SUM 931 of 2025 the father sought sole care and control, sole authority over education and health, orders against what he called parental alienation, a penal notice against the mother, and changes to holiday, overseas and special-day access. The child had by then started primary school. The father, who acted in person, had not been in full-time work since losing a job paying $7,000 in March 2020.

Issues

1. Whether care and control should be reversed to the father, and whether orders against parental alienation and a penal notice against the mother were justified.
2. Whether either parent should have sole authority over the child's education and healthcare decisions.
3. How the father's regular, school vacation, holiday and special-date access should be restructured now that the child was in primary school.
4. Whether child maintenance should be varied to a fixed sum, in what amount, and from when.

Holding

The court varied the consent order and replaced its terms. It dismissed the father's prayers to reverse care and control, for anti-alienation orders, to restrict the mother's change of residence and on religious matters, but inserted a penal notice applying to both parents. The mother was given sole authority over day-to-day education and healthcare matters, subject to stated consultation and notice duties, and access was restructured with a priority ranking and no make-up access. Maintenance became a fixed $350 per month from June 2022 to February 2026 and $575 a month from March 2026. The father was ordered to pay costs of $4,000.00 in FC/SUM 2583 of 2024 and $3,000.00 in FC/SUM 931 of 2025, with each party bearing its own costs in FC/SUM 1680 of 2024.

Reasoning

On care and control, the court found the father's allegations of custody breaches mostly unfounded and based on a wrong view of the law, as explained in CX v CY [2005] 3 SLR(R) 690. He repeated them even after the committal decision rejected them. The four instances of lost access were not breaches, since the mother was using powers the order gave her or the order did not prescribe how holidays were split. Schools communicating through the care and control parent was not alienation. The court refused to let his unemployment be used to engineer a reversal.

On decision-making, the father's delayed and hurtful emails during primary school registration, and his conduct with two preschools that ended the child's enrolment, showed a combative approach unsuited to co-parenting. The court therefore made the mother the sole contact with the school and gave her authority over tuition, enrichment and routine medical care, while keeping secondary school choice and hospitalisation as joint custody matters and giving the father access to the ClassDojo application and report books.

On access, the court reduced the Thursday access to once a month to give the child a steadier school routine, set out alternating weekly vacation blocks and alternating holidays, and ranked the access types to avoid disputes.

On maintenance, following WBU v WBT [2023] SGHCF 3, the court moved to a fixed budget to ease enforcement. It found the father could earn about what the mother earned, so the child's assessed expenses were split equally. The mother's past expenses were reasonable, and the father's claims about his own spending were unsupported.

From the judgment