Goh Yong Hng v Cheong Yen Teng: Appeal for Private Investigator Costs in Adultery Divorce Case
In Goh Yong Hng v Cheong Yen Teng, the High Court of Singapore heard an appeal by the husband, Goh Yong Hng, regarding the proportion of private investigator costs the co-respondent, Goh Yik Liang, should bear in a divorce case based on the wife's adultery. The District Court had ordered the co-respondent to pay 25% of the investigation costs. Judith Prakash J allowed the appeal in part, increasing the co-respondent's share to half of the reasonable investigation costs, totaling $3,890.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Appeal Allowed in Part
1.3 Case Type
Family
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal regarding co-respondent's share of private investigator costs in an adultery-based divorce. The court partially allowed the appeal, increasing the co-respondent's share.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Goh Yong Hng | Petitioner, Appellant | Individual | Appeal Allowed in Part | Partial | |
| Cheong Yen Teng (Zheng Yanping) (m.w.) | Respondent | Individual | Divorce Granted | Neutral | |
| Goh Yik Liang | Co-Respondent, Respondent | Individual | Costs Awarded Against | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Judith Prakash | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Irving Choh | CTLC Law Corporation |
| Angela Lee | Jansen, Menon & Lee |
4. Facts
- The husband filed for divorce based on the wife's adultery with the co-respondent.
- The husband hired private investigators to gather evidence of the adultery.
- The wife and co-respondent were observed entering a flat in Bishan.
- The co-respondent initially offered to pay the investigator's fees.
- The district judge ordered the co-respondent to pay 25% of the investigator's costs.
- The husband appealed, seeking full reimbursement of the investigation costs from the co-respondent.
- The wife did not contest the divorce petition.
5. Formal Citations
- Goh Yong Hng v Cheong Yen Teng (Zheng Yanping) (m.w.) and Another, Div P 602501/2002, RAS 720104/2002, [2003] SGHC 89
6. Timeline
| Date | Event |
|---|---|
| Husband, wife, and co-respondent first met. | |
| Husband instructed private investigator. | |
| Wife and co-respondent committed adultery in a flat in Bishan. | |
| Meeting of the three parties took place. | |
| Divorce petition filed by husband. | |
| Petition heard in court. | |
| Appeal decision date. |
7. Legal Issues
- Admissibility of Private Investigator Costs
- Outcome: The court held that the co-respondent was liable for half of the reasonable investigation costs.
- Category: Substantive
- Sub-Issues:
- Reasonableness of costs
- Necessity of surveillance
- Proportion of costs payable by co-respondent
- Grounds for Divorce
- Outcome: The court was satisfied that the husband had sufficiently proved the contents of his petition and granted the decree nisi.
- Category: Substantive
- Sub-Issues:
- Adultery
- Irretrievable breakdown of marriage
8. Remedies Sought
- Divorce
- Costs of Divorce Proceedings
- Reimbursement of Private Investigator Costs
9. Cause of Actions
- Adultery
- Irretrievable Breakdown of Marriage
10. Practice Areas
- Divorce Litigation
- Family Law
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Tan Kay Poh v Tan Surida & Anor | High Court | Yes | [1988] SLR 983 | Singapore | Distinguished from the present case because in Tan Kay Poh, the wife had left the matrimonial home before the adulterous relationship began, whereas in the present case, the parties were still living together. |
13. Applicable Rules
| Rule Name |
|---|
| Matrimonial Proceedings Rules r 2 |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Rules of Court O 59 r 27(2) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Adultery
- Private Investigator
- Costs
- Co-Respondent
- Surveillance
- Reasonableness
- Matrimonial Proceedings
- Breakdown of Marriage
15.2 Keywords
- divorce
- adultery
- private investigator
- costs
- Singapore
- family law
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Family Law | 95 |
| Adultery | 90 |
| Divorce | 90 |
| Costs | 80 |
| Ancillary Orders | 70 |
| Private Investigators | 60 |
| Evidence Law | 60 |
| Damages | 50 |
| Citizenship | 1 |
| Children's Welfare | 1 |
| Child Support | 1 |
| Child Custody | 1 |
16. Subjects
- Family Law
- Divorce
- Civil Procedure
- Costs