Goh Eng Hong v Management Corporation: Personal Injury Damages Assessment for Lift Accident
In Goh Eng Hong v Management Corporation of Textile Centre, the Singapore High Court heard an appeal by the Second Defendants against the damages assessed and awarded to Goh Eng Hong by an Assistant Registrar for injuries sustained in a lift accident at Textile Centre. Goh, who was working as a host mamasan, suffered fractures and post-traumatic stress disorder. The High Court reduced the awards for the fractures, post-traumatic stress disorder, and post-trial loss of income, but upheld the award for pre-trial loss of earnings.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Appeal allowed in part; awards for fracture of the left tibia and fibula, fracture of the medial malleolus of left ankle, post-traumatic stress disorder, and post-trial loss of income were reduced; award for pre-trial loss of earnings was upheld.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
High Court appeal regarding damages awarded to Goh Eng Hong for injuries sustained in a lift accident, focusing on loss of earnings and PTSD.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Another | Defendant, Respondent | Other | Appeal allowed in part | Partial | |
| Goh Eng Hong | Plaintiff | Individual | Appeal allowed in part | Partial | |
| Management Corporation of Textile Centre | Defendant, Respondent | Corporation | Appeal allowed in part | Partial |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Kan Ting Chiu | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Dinesh Singh Dhillon | Khattar Wong & Partners |
| Leonard Lim Kian Wee | Thomas Tham & Co |
4. Facts
- Plaintiff injured in a lift accident at Textile Centre on 3 May 1997.
- Plaintiff was 51 years old and working as a host mamasan at the time of the accident.
- Plaintiff sustained an open compound fracture of the left tibia and fibula and a closed fracture of the medial malleolus of the left ankle.
- Plaintiff developed post-traumatic stress disorder after the accident.
- Plaintiff did not resume work after the accident due to injuries and PTSD.
- Assistant Registrar initially assessed damages at $415,341.79.
- The High Court reduced some of the damages awarded by the Assistant Registrar.
5. Formal Citations
- Goh Eng Hong v Management Corporation of Textile Centre And Another, Suit 307/1998, [2000] SGHC 97
6. Timeline
| Date | Event |
|---|---|
| Accident occurred; Plaintiff injured in lift at Textile Centre. | |
| Plaintiff discharged from hospital. | |
| Plaintiff underwent posterolateral bone grafting. | |
| Plaintiff underwent left eye surgery for cataracts. | |
| Plaintiff's wounds had healed well. | |
| Plaintiff underwent acute shortening and Ilizarov distraction osteotomy of the left tibia. | |
| Plaintiff underwent limited bone grafting. | |
| Frame removed from Plaintiff's leg. | |
| Plaintiff underwent right eye surgery for cataracts. | |
| Assistant Registrar assessed damages for the Respondent. | |
| High Court decision date. |
7. Legal Issues
- Measure of Damages for Personal Injuries
- Outcome: The court reduced the awards for fracture of the left tibia and fibula, fracture of the medial malleolus of left ankle, post-traumatic stress disorder, and post-trial loss of income.
- Category: Substantive
- Sub-Issues:
- Loss of future earnings
- Appropriate multiplier
- Evidence to support higher multiplicand for post-trial earnings
- Quantum for fracture of tibia and fibula
- Quantum for fracture of medial malleolus of ankle
- Quantum for post-traumatic stress disorder
8. Remedies Sought
- Damages for personal injuries
- Loss of earnings
9. Cause of Actions
- Negligence
10. Practice Areas
- Personal Injury Litigation
11. Industries
- Entertainment
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Pang Koi Fa v Lim Djoe Phing | N/A | Yes | [1993] 3 SLR 317 | Singapore | Cited as a precedent for an award for post-traumatic stress disorder, but distinguished due to the presence of pathological grief in the cited case. |
| Lai Wee Lian v Singapore Bus Service (1978) Ltd | N/A | Yes | [1984-1985] SLR 10 | Singapore | Cited for the principle that discounts should be made for contingencies and accelerated receipt when assessing lost future income. |
| Alagamalai s/o Veerasamy v Chan Lian Chan | N/A | Yes | November 1994 MMD 1603 | Singapore | Cited as a precedent award for fractures of the tibia and fibula with residual disabilities. |
| Lai Sin Wah v Ng Soo Ngoh | N/A | Yes | January 1999 MCL 72 | Singapore | Cited as a precedent award for fractures of the tibia and fibula with residual disabilities. |
| Parakatt Sajeev s/o Kunniyer Damodara Kurup v Camperon Bernard – Singapore Piling Civil Contractors Pte Ltd | N/A | Yes | [1996] MD 991 | Singapore | Cited as an older award for similar fractures with residual disabilities. |
| Lee Wee Yee & Anor v Koh Geok Chee & Ors | N/A | Yes | December 1992 MMD 1574 | Singapore | Cited as a precedent award for a closed fracture of the medial malleolus with stiffness of the ankle. |
| Mohamad Aliman bin Kassim v Zulkifli bin Abdul Latib & Anor | N/A | Yes | 1998 MD 1750 | Singapore | Cited as a precedent award for an open fracture of the right medial malleolus with puncture wound. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| No applicable statutes | |
15. Key Terms and Keywords
15.1 Key Terms
- Host mamasan
- Multiplier
- Multiplicand
- Post-traumatic stress disorder
- Fracture of tibia
- Fracture of fibula
- Fracture of medial malleolus
- Loss of earnings
- Ilizarov distraction
- Dorsiflexion
15.2 Keywords
- personal injury
- damages
- lift accident
- fracture
- post-traumatic stress disorder
- loss of earnings
- mamasan
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Personal Injury | 90 |
| Measure of Damages | 90 |
| Damages Assessment | 90 |
| Post-Traumatic Stress Disorder | 70 |
| Negligence | 50 |
| Psychiatry | 30 |
16. Subjects
- Personal Injury
- Damages
- Civil Procedure