Parkway Hospitals v Sandar Aung: Contractual Liability for Hospital Expenses Exceeding Initial Estimate
In the High Court of Singapore, Parkway Hospitals Singapore Pte Ltd and Mount Elizabeth Medical Holdings Ltd sued Sandar Aung to recover $537,432.34 for medical services rendered to Aung's mother. Aung signed an agreement to be liable for her mother's hospital expenses. The court, presided over by Judith Prakash J, found Aung liable for $320,083.77, representing hospital charges incurred before the transfer of the hospital's business to Parkway, but not for the doctors' fees.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Judgment for the plaintiffs.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Parkway Hospitals sued Sandar Aung for unpaid medical bills of her mother. The court found Aung liable for hospital charges incurred.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Parkway Hospitals Singapore Pte Ltd (trading as Mount Elizabeth Hospital) | Plaintiff | Corporation | Judgment for Plaintiff | Won | Lek Siang Pheng, Mar Seow Hwei |
| Mount Elizabeth Medical Holdings Ltd (formerly known as Elizabeth Hospital Ltd.) | Plaintiff | Corporation | Judgment for Plaintiff | Won | Lek Siang Pheng, Mar Seow Hwei |
| Sandar Aung | Defendant | Individual | Judgment against Defendant | Lost | James Leslie Ponniah, Leong Sue Lynn |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Judith Prakash | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Lek Siang Pheng | Rodyk & Davidson |
| Mar Seow Hwei | Rodyk & Davidson |
| James Leslie Ponniah | Wong & Lim |
| Leong Sue Lynn | Wong & Lim |
4. Facts
- Mdm Tin Nyunt was admitted to Mount Elizabeth Hospital for an angioplasty.
- Sandar Aung signed an agreement to be liable for her mother's hospital expenses.
- The initial estimated hospital charges were $15,227.30.
- Mdm Tin Nyunt suffered complications and had a lengthy stay in the hospital.
- The final hospital bill was $537,432.34.
- MEM Holdings assigned its business and assets to Parkway.
- Parkway sued Sandar Aung for the unpaid medical bill.
5. Formal Citations
- Parkway Hospitals Singapore Pte Ltd (trading as Mount Elizabeth Hospital) and Another v Sandar Aung, Suit 68/2006, [2006] SGHC 200
6. Timeline
| Date | Event |
|---|---|
| Mdm Tin Nyunt admitted to Mount Elizabeth Hospital for angioplasty. | |
| Sandar Aung signed an agreement with Mount Elizabeth Medical Holdings Ltd agreeing to be liable for expenses incurred by Mdm Tin Nyunt. | |
| Hospital business, assets, and liabilities of MEM Holdings transferred to Parkway Hospitals Singapore Pte Ltd. | |
| Mdm Tin Nyunt discharged from the hospital. | |
| Parkway sent Mdm Tin Nyunt an invoice for $537,432.34. | |
| Action commenced against Sandar Aung. | |
| Judgment given in favor of the plaintiffs. |
7. Legal Issues
- Breach of Contract
- Outcome: The court found the defendant liable for breach of contract.
- Category: Substantive
- Enforceability of Assignment
- Outcome: The court held that the assignment was enforceable after MEM Holdings was added as a plaintiff.
- Category: Procedural
- Construction of Contractual Terms
- Outcome: The court construed the agreement to mean that the defendant was liable for all hospital charges incurred, not just the estimated amount.
- Category: Substantive
8. Remedies Sought
- Monetary Damages
9. Cause of Actions
- Breach of Contract
10. Practice Areas
- Commercial Litigation
11. Industries
- Healthcare
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Lexi Holdings plc v Garth Scott Stainforth | English Court of Appeal | Yes | [2006] EWCA Civ 988 | England and Wales | Cited for the application of the contra proferentem rule. |
| Tam Wing Chuen v Bank of Credit and Commerce Hong Kong Ltd | N/A | Yes | [1996] 2 BCLC 69 | Hong Kong | Cited for the basis of the contra proferentem principle. |
| Pacific Century Regional Developments Ltd v Estate of Seow Khoon Seng | Court of Appeal | Yes | [1997] 3 SLR 761 | Singapore | Cited for the objective approach to construing a contract. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| No applicable statutes | |
15. Key Terms and Keywords
15.1 Key Terms
- Assignment
- Contractual Liability
- Hospital Expenses
- Medical Services
- Estimate
- Financial Obligation
- Undertaking
15.2 Keywords
- contract
- hospital
- medical
- expenses
- liability
- assignment
16. Subjects
- Contract Law
- Healthcare
- Debt Recovery
17. Areas of Law
- Contract Law
- Assignment