Ang Leng Hock v Leo Ee Ah: Negligence, Damages Assessment & Loss of Future Earnings
In Ang Leng Hock v Leo Ee Ah, the High Court of Singapore heard appeals from both the plaintiff, Ang Leng Hock, and the defendant, Leo Ee Ah, following an assessment of damages related to a motorcycle accident. The primary legal issues concerned the appropriate calculation of loss of future earnings, the admissibility of further evidence on appeal, and the multiplier for future medical expenses. The court allowed both appeals in part, adjusting the awards for pre-trial loss of earnings, future loss of earning capacity, and future medical expenses.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Both appeals allowed in part.
1.3 Case Type
Civil
1.4 Judgment Type
Judgment reserved
1.5 Jurisdiction
Singapore
1.6 Description
Appeal regarding damages assessment after a motorcycle accident. The court addressed loss of future earnings, medical expenses, and admissibility of new evidence.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Ang Leng Hock | Plaintiff, Appellant | Individual | Appeal allowed in part | Partial | |
| Leo Ee Ah | Defendant, Respondent | Individual | Appeal allowed in part | Partial |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Judith Prakash | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Gurdeep Singh | K S Chia Gurdeep and Param |
| Lee Yuk Lan | Goh Poh and Partners |
4. Facts
- Ang Leng Hock was injured in a motorcycle accident on 29 January 1999 involving a taxi driven by Leo Ee Ah.
- Interlocutory judgment was entered for Ang Leng Hock, with damages to be assessed, and Leo Ee Ah was liable for 95% of the damages.
- Ang Leng Hock worked as an independent contractor for Grand Court Vegetarian Restaurant before the accident.
- Ang Leng Hock also had a part-time job as a deliveryman for Smith & Nephew Pte Ltd.
- After the accident, Ang Leng Hock was unable to perform his duties for Grand Court due to his injuries.
- Ang Leng Hock started a coffee shop business after the accident.
- The assistant registrar made awards for pain and suffering, loss of future earnings, future medical expenses, pre-trial loss of earnings, and other expenses.
5. Formal Citations
- Ang Leng Hock v Leo Ee Ah, Suit 256/2000, RA 382/2003, 385/2003, SIC 7063/2003, [2004] SGHC 55
6. Timeline
| Date | Event |
|---|---|
| Motorcycle accident occurred involving Ang Leng Hock and Leo Ee Ah. | |
| Action started by Ang Leng Hock. | |
| Interlocutory judgment entered for the plaintiff for damages to be assessed. | |
| Assessment hearing took place before the assistant registrar over three days. | |
| Assistant registrar's judgment delivered. | |
| Appeals fixed for hearing. | |
| Judgment reserved. |
7. Legal Issues
- Admissibility of Further Evidence on Appeal
- Outcome: The court held that the principles in Ladd v Marshall applied to the adduction of fresh evidence on an appeal to the judge in chambers from an assessment of damages hearing before the registrar.
- Category: Procedural
- Related Cases:
- [2003] 3 SLR 666
- [1954] 1 WLR 1489
- [1999] 2 SLR 233
- Loss of Future Earnings
- Outcome: The court set aside the award for future loss of earnings and awarded damages for loss of earning capacity instead.
- Category: Substantive
- Multiplier for Future Medical Expenses
- Outcome: The court reduced the multiplier for future medical costs from 20 to 15 years.
- Category: Substantive
8. Remedies Sought
- Damages
9. Cause of Actions
- Negligence
10. Practice Areas
- Personal Injury
- Civil Litigation
11. Industries
- Food and Beverage
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Lassiter Ann Masters v To Keng Lam | High Court | Yes | [2003] 3 SLR 666 | Singapore | Cited for the principle that the principles in Ladd v Marshall apply to Registrar's Appeals. |
| Ladd v Marshall | N/A | Yes | [1954] 1 WLR 1489 | England and Wales | Cited for the principles governing the admission of new evidence on appeal. |
| Chang Ah Lek v Lim Ah Koon | Court of Appeal | Yes | [1999] 1 SLR 82 | Singapore | Cited regarding the manner in which a judge in chambers deals with an appeal from the registrar on the merits. |
| Herbs and Spices Trading Post Pte Ltd v Deo Silver (Pte) Ltd | District Court | Yes | [1990] SLR 1234 | Singapore | Cited regarding the jurisdiction of a district judge in hearing appeals from the registrar of the District Court. |
| Lian Soon Construction Pte Ltd v Guan Qian Realty Pte Ltd | Court of Appeal | Yes | [1999] 2 SLR 233 | Singapore | Cited regarding the discretion of a judge in chambers to admit fresh evidence on appeal from the registrar. |
| Wee Sia Tian v Long Thik Boon | N/A | Yes | [1996] 3 SLR 513 | Singapore | Cited regarding the calculation of the length of the multiplier for loss of earnings. |
| Surendamugam s/o Narayanasamy v Low Chong Hock | High Court | Yes | [1993] SGHC 130 | Singapore | Cited regarding the calculation of the length of the multiplier for loss of earnings. |
13. Applicable Rules
| Rule Name |
|---|
| Rules of Court (Cap 322, R 5, 1997 Rev Ed) |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Retirement Age Act (Cap 274A, 2000 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Assessment of damages
- Loss of future earnings
- Loss of earning capacity
- Multiplier
- Medical expenses
- Registrar's appeal
- Further evidence
- Grand Court Vegetarian Restaurant
- Smith & Nephew
15.2 Keywords
- Motorcycle accident
- Damages assessment
- Loss of earnings
- Medical expenses
- Singapore
- High Court
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Damages | 90 |
| Assessment of Damages | 85 |
| Negligence | 80 |
| Personal Injury | 80 |
| Civil Litigation | 75 |
| Loss of future earnings | 70 |
| Civil Procedure | 70 |
| Loss of Earning Capacity | 70 |
16. Subjects
- Personal Injury
- Damages
- Civil Procedure