Lau Liat Meng & Co v Lum Kai Keng: Review of Taxation of Costs and Interim Bills
In Lau Liat Meng & Co v Lum Kai Keng, the High Court of Singapore reviewed the taxation of costs for legal services provided by Lau Liat Meng & Co to Lum Kai Keng concerning the administration of her deceased husband's estate. The court, presided over by Judicial Commissioner Choo Han Teck, considered the implications of interim bills rendered by the solicitors and their entitlement to claim further costs for the same period. Ultimately, the court dismissed the solicitors' application and allowed Lum Kai Keng's application, reducing the awarded costs.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Application of Lau Liat Meng & Co dismissed; application of Lum Kai Keng allowed.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
The High Court reviewed the taxation of costs, focusing on interim bills and the duty of lawyers to provide clear and accurate billing. The court reduced the awarded costs.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Lau Liat Meng & Co | Applicant | Corporation | Application Dismissed | Lost | Andre Arul |
| Lum Kai Keng | Respondent | Individual | Application Allowed | Won | Wong Siew Hong |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Choo Han Teck | Judicial Commissioner | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Andre Arul | C Arul & Partners |
| Wong Siew Hong | Infinitus Law Corp |
4. Facts
- Lau Liat Meng & Co rendered legal services to Lum Kai Keng regarding the administration of her deceased husband's estate.
- The legal work became contentious, leading to litigation against Lum Kai Keng's son, daughter, and Keppel Tatlee Bank Ltd.
- Lau Liat Meng & Co rendered two interim bills for $15,000 and $30,000, respectively, which were paid by Lum Kai Keng.
- A dispute arose regarding the final bill of costs, with Lau Liat Meng & Co claiming $220,000 for 446 hours of work.
- The assistant registrar taxed off $110,000, allowing $110,000, and increased the sum under section 2 from $1,200 to $1,500.
- Both parties applied to review the taxed costs before a judge in chambers.
- The court found that Lau Liat Meng & Co was only entitled to bill for work done after the second interim bill.
5. Formal Citations
- Lau Liat Meng & Co v Lum Kai Keng, BOC 600475/2001, SIC 600685/2002, SIC 600686/2002, [2002] SGHC 159
6. Timeline
| Date | Event |
|---|---|
| Legal services commenced by Lau Liat Meng & Co | |
| First interim bill rendered for services from March 1998 | |
| First interim bill paid | |
| KS Chung engaged as second counsel | |
| Lau Liat Meng & Co wrote to Madam Lum regarding payment | |
| Second interim bill rendered (approximately end of December) | |
| Period covered by bill of costs ends | |
| Bill of costs 600475 rendered | |
| Judgment issued |
7. Legal Issues
- Taxation of Costs
- Outcome: The court determined the appropriate amount to be allowed for legal services, taking into account interim bills and the nature of the work done.
- Category: Procedural
- Sub-Issues:
- Interim bill
- Review of taxation
- Duty of Lawyer
- Outcome: The court emphasized the duty of a lawyer to draw up bills clearly and accurately, ensuring clients are not misled about the actual fees incurred.
- Category: Substantive
- Sub-Issues:
- Clarity and accuracy of billing
- Disclosure of fees
8. Remedies Sought
- Review of Taxation of Costs
9. Cause of Actions
- Solicitor and Client Costs Dispute
10. Practice Areas
- Litigation
- Legal Fee Disputes
11. Industries
- Legal Services
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Tan Boon Hai (on behalf of himself and all other unsuccessful candidates in the Singapore Hainan Hwee Kuan 1999/2000 Management Committee Elections) v Lee Ah Fong | Court of Appeal | Yes | [2002] 1 SLR 10 | Singapore | Cited for the principle that a judge hearing an application for review of taxation of costs hears the matter de novo and is not fettered by the registrar's discretion. |
13. Applicable Rules
| Rule Name |
|---|
| O 59 r 28(4) Rules of Court |
| O 59 r 36 Rules of Court |
| O 59 r 28(2)(a) |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Rules of Court | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Interim bill
- Taxation of costs
- Solicitor and client costs
- Review of taxation
- Hourly rate
- Reasonable costs
- Duty of lawyer
15.2 Keywords
- taxation
- costs
- interim bill
- legal fees
- solicitor
- client
16. Subjects
- Civil Procedure
- Legal Costs
- Professional Responsibility
17. Areas of Law
- Civil Procedure
- Costs
- Taxation