Teo Choo Him v Teo Leng Hui: Dispute over Appointment of Committee for Patient with Brain Damage

In Teo Choo Him and Another v Teo Leng Hui, the High Court of Singapore addressed a dispute between the parents (Teo Choo Him and Chua Ah Bee) and the husband (Tan Choon Leong) of Teo Leng Hui, who suffered severe brain damage. The parents sought to be appointed as the committee of the person and estate of their daughter under the Mental Disorders and Treatment Act. The husband intervened, seeking the same appointment. Tay Yong Kwang J appointed the husband, emphasizing the importance of family unity and the patient's right to be with her husband and child.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Respondent's husband appointed committee of person and estate of respondent.

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

High Court case between parents and husband over who should be appointed committee for a patient with brain damage. The court appointed the husband.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Teo Choo HimApplicantIndividualApplication DismissedLost
Chua Ah BeeApplicantIndividualApplication DismissedLost
Teo Leng HuiRespondentIndividual
Tan Choon LeongOtherIndividualAppointed committee of the person and estate of the patientWon

3. Judges

Judge NameTitleDelivered Judgment
Tay Yong KwangJudgeYes

4. Counsels

4. Facts

  1. The patient suffered severe brain damage after undergoing a Caesarean section.
  2. The patient has been cared for by her parents since July 2001.
  3. The patient is of unsound mind and incapable of managing herself and her affairs.
  4. The patient's parents and husband both sought to be appointed as the committee for her person and estate.
  5. The husband stopped visiting the patient regularly due to the strained relationship with the parents.
  6. The husband wants to bring his wife home to be cared for by him and his mother.
  7. The patient and her husband jointly own accounts and shares in the matrimonial home.

5. Formal Citations

  1. Teo Choo Him and Another v Teo Leng Hui, OS 133/2005, [2005] SGHC 97

6. Timeline

DateEvent
Patient was born.
Patient married Tan Choon Leong.
Patient underwent elective Caesarean section.
Patient suffered severe brain damage.
Patient transferred to Mount Elizabeth Hospital.
Patient discharged from Mount Elizabeth Hospital and moved to her parents’ home.
Patient to be transferred from the applicants’ home to the matrimonial home.
Tan is to take vacation leave to help the patient adjust to her new surroundings.
Decision Date

7. Legal Issues

  1. Appointment of Committee for Person of Unsound Mind
    • Outcome: The court appointed the husband as the committee of the person and estate of the patient.
    • Category: Substantive
    • Related Cases:
      • [1990] 2 MLJ 460
      • [1989] 2 MLJ 89
      • (1978) 87 DLR (3d) 192

8. Remedies Sought

  1. Appointment as committee of the person and estate

9. Cause of Actions

  • No cause of actions

10. Practice Areas

  • Mental Capacity
  • Guardianship

11. Industries

  • No industries specified

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
See Wan Chon v Chua Ka BuHigh CourtYes[1990] 2 MLJ 460SingaporeCited for the definition of 'unsound mind' under common law and the Mental Disorders and Treatment Act.
Prem Singh v Kirpal SinghHigh CourtYes[1989] 2 MLJ 89SingaporeCited for the principle that the court's jurisdiction under the Act should be exercised for the benefit of the mentally disordered person.
Re West and WestN/ANo(1978) 87 DLR (3d) 192CanadaCited to support the argument that authorized applicants under s 4 of the Act do not automatically have a special right to be appointed the committee.

13. Applicable Rules

Rule Name
O 76 r 1 of the Rules of Court (Cap 322, R 5, 2004 Rev Ed)
O 71 r 19 of the Rules of Court

14. Applicable Statutes

Statute NameJurisdiction
Mental Disorders and Treatment Act (Cap 178, 1985 Rev Ed)Singapore
Rules of Court (Cap 322, R 5, 2004 Rev Ed)Singapore
Probate and Administration Act (Cap 251, 2000 Rev Ed)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Committee of the person
  • Committee of the estate
  • Unsound mind
  • Mental Disorders and Treatment Act
  • Matrimonial home
  • Pulmonary embolism

15.2 Keywords

  • mental disorder
  • unsound mind
  • committee
  • family dispute
  • guardianship

17. Areas of Law

16. Subjects

  • Mental Capacity Law
  • Guardianship
  • Family Dispute Resolution