Sri Jaya v RHB Bank: Interpretation of Consent Judgment & Interest Calculation
In Sri Jaya (Sdn) Bhd v RHB Bank Bhd, the Singapore High Court addressed a dispute regarding the calculation of interest under a 1991 consent judgment. Sri Jaya had borrowed money from RHB Bank to develop property, leading to the 1991 judgment ordering the sale of the property. After a subsequent lawsuit (Suit No. 253/99) where Sri Jaya obtained judgment against RHB for negligence, differences arose regarding the interest calculation on the initial 1991 judgment. The court ruled that pre-judgment interest should be calculated on a simple interest basis, while post-judgment interest should be calculated on the composite sum of principal plus interest up to the date of the 1991 judgment.
1. Case Overview
1.1 Court
High Court1.2 Outcome
The court ruled that pre-judgment interest was to be calculated on a simple interest basis and post-judgment interest should be calculated on the composite sum of principal plus interest up to the date of the judgment.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
The High Court ruled on the calculation of pre- and post-judgment interest concerning a 1991 consent judgment between Sri Jaya and RHB Bank.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| RHB Bank Bhd | Defendant, Respondent | Corporation | Partial | Partial | |
| Sri Jaya (Sdn) Bhd | Plaintiff, Applicant | Corporation | Partial | Partial |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| S Rajendran | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Tan Bar Tien | BT Tan & Co |
| Denis Tan | Toh Tan & Pnrs |
4. Facts
- Sri Jaya borrowed money from RHB Bank to develop property.
- A consent judgment was entered against Sri Jaya in 1991.
- The property was sold for $6.5 million.
- Sri Jaya sued RHB for negligence in handling the sale and won.
- Disputes arose over the calculation of interest under the 1991 judgment.
5. Formal Citations
- Sri Jaya (Sdn) Bhd v RHB Bank Bhd, OS 600160/2001, OS 600160/2001
6. Timeline
| Date | Event |
|---|---|
| RHB Bank commenced legal proceedings against Sri Jaya in Suit No. 5904 of 1983. | |
| Consent judgment was entered against Sri Jaya in Suit No. 5904 of 1983. | |
| Sale of the property was completed. | |
| RHB Bank sent a letter to Sri Jaya informing them of a shortfall after the sale. | |
| Sri Jaya commenced proceedings against RHB Bank in Suit No. 253/99 for negligence. | |
| Sri Jaya obtained judgment against RHB Bank in Suit No. 253/99. | |
| Court ruled on the calculation of interest under the 1991 judgment. |
7. Legal Issues
- Interest Calculation
- Outcome: The court ruled that pre-judgment interest was to be calculated on a simple interest basis and post-judgment interest should be calculated on the composite sum of principal plus interest up to the date of the judgment.
- Category: Substantive
- Sub-Issues:
- Simple interest vs. compound interest
- Calculation of post-judgment interest
8. Remedies Sought
- Determination of interest calculation method
9. Cause of Actions
- Breach of Contract
- Negligence
10. Practice Areas
- Commercial Litigation
- Banking Litigation
11. Industries
- Banking
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Diversey (Far East) Pte Ltd v Chai Chung Ching Chester & Ors | High Court | Yes | [1993] 1 SLR 535 | Singapore | Cited regarding construing the meaning of words in a judgment by looking into underlying documents, but distinguished on the facts. |
13. Applicable Rules
| Rule Name |
|---|
| Order 42 rule 12 of the Rules of Court |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Civil Law Act (Ch 43, 1994 Ed) s 9 | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Consent judgment
- Pre-judgment interest
- Post-judgment interest
- Simple interest
- Compound interest
- Composite sum
15.2 Keywords
- interest
- judgment
- consent
- simple
- compound
- civil law act
- negligence
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Interest | 90 |
| Judgments and Orders | 80 |
| Contract Law | 75 |
| Civil Procedure | 60 |
| Banking and Finance | 50 |
16. Subjects
- Banking
- Finance
- Debt Recovery
- Interest