Sandar Aung v Parkway Hospitals: Contractual Terms & Hospital Bill Dispute
In Sandar Aung v Parkway Hospitals Singapore Pte Ltd, the Court of Appeal of Singapore heard an appeal on March 30, 2007, regarding a contractual dispute over a hospital bill. Sandar Aung, the appellant, challenged the decision to hold her liable for a hospital bill that greatly exceeded the initial estimate for her mother's angioplasty. The court allowed the appeal, finding that the contract's scope was limited to the angioplasty procedure, and not the subsequent unforeseen medical complications. The claim was based on a breach of contract claim.
1. Case Overview
1.1 Court
Court of Appeal1.2 Outcome
Appeal Allowed
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal regarding a hospital bill exceeding the estimate. The court allowed the appeal, construing the contract scope as limited to the angioplasty procedure.
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 | Respondent | Corporation | Appeal Dismissed | Lost | |
| Sandar Aung | Appellant | Individual | Appeal Allowed | Won | |
| Mount Elizabeth Medical Holdings Ltd (formerly known as Mount Elizabeth Hospital Ltd) | Respondent | Corporation | Appeal Dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Andrew Ang J | Judge | No |
| Chan Sek Keong CJ | Chief Justice | No |
| Andrew Phang Boon Leong JA | Justice of the Court of Appeal | Yes |
4. Counsels
4. Facts
- Appellant's mother admitted to Mount Elizabeth Hospital for angioplasty on January 7, 2004.
- Appellant signed an 'Estimate of Hospital Charges' and a 'Conditions of Services/Hospital Policies' document.
- The estimate for the angioplasty was $15,227.30.
- The angioplasty did not have the intended outcome, requiring urgent open heart bypass surgery.
- Patient suffered multiple complications, including a stroke, infection, and gangrene, requiring 11 months of hospitalization.
- Hospital rendered an invoice for $537,432.34 after deposit payments.
- Appellant denied liability, arguing the undertaking was limited to the angioplasty procedure.
5. Formal Citations
- Sandar Aung v Parkway Hospitals Singapore Pte Ltd (trading as Mount Elizabeth Hospital) and Another, CA 102/2006, [2007] SGCA 20
6. Timeline
| Date | Event |
|---|---|
| Patient admitted to Mount Elizabeth Hospital for angioplasty | |
| Corporate restructuring; assets transferred from second respondent to first respondent | |
| Patient discharged from hospital | |
| Judgment reserved |
7. Legal Issues
- Breach of Contract
- Outcome: The court held that the contract's scope was limited to the angioplasty procedure, not covering subsequent unforeseen medical complications.
- Category: Substantive
- Sub-Issues:
- Scope of contractual terms
- Construction of contract
- Interpretation of undertaking
- Related Cases:
- [2007] 1 SLR 227
- Construction of Contract
- Outcome: The court determined that the factual matrix, including the Estimate, demonstrated that the contract was confined to the angioplasty procedure.
- Category: Substantive
- Sub-Issues:
- Relevance of factual matrix
- Parol evidence rule
- Intention of parties
- Related Cases:
- [1996] 2 WLR 726
- [1976] 1 WLR 989
- [2005] 2 SLR 509
- [1998] 1 WLR 896
- [2002] 1 AC 251
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 |
|---|---|---|---|---|---|
| Parkway Hospitals Singapore Pte Ltd (trading as Mount Elizabeth Hospital) v Sandar Aung | High Court | No | [2007] 1 SLR 227 | Singapore | Cited for the trial judge's decision that the contract was binding and the appellant was liable to pay for all medical services provided. |
| Charter Reinsurance Co Ltd v Fagan | House of Lords | Yes | [1996] 2 WLR 726 | England and Wales | Cited for the principle that the meaning of words is sensitive to syntax and context. |
| Reardon Smith Line Ltd v Yngvar Hansen-Tangen | House of Lords | Yes | [1976] 1 WLR 989 | England and Wales | Cited for the principle that the court should place itself in the same factual matrix as the parties when construing a contract. |
| China Insurance Co (Singapore) Pte Ltd v Liberty Insurance Pte Ltd | High Court | Yes | [2005] 2 SLR 509 | Singapore | Cited for endorsing the common law principle of considering the factual matrix when construing contracts. |
| Investors Compensation Scheme Ltd v West Bromwich Building Society | House of Lords | Yes | [1998] 1 WLR 896 | England and Wales | Cited for the principles of contractual interpretation, including considering the background knowledge reasonably available to the parties. |
| Bank of Credit and Commerce International SA v Ali | House of Lords | Yes | [2002] 1 AC 251 | England and Wales | Cited for the principle that there is no conceptual limit to what can be regarded as background in contractual interpretation. |
| The Commercial Bank of Australia Limited v Amadio | High Court | No | (1983) 151 CLR 447 | Australia | Cited in relation to the doctrine of unconscionability. |
| William Brandt’s Sons & Co v Dunlop Rubber Company, Limited | House of Lords | Yes | [1905] AC 454 | England and Wales | Cited regarding the validity of the assignment as an equitable assignment. |
| Prenn v. Simmonds | N/A | Yes | [1971] 1 W.L.R. 1381 | N/A | Cited as a case that led to a fundamental change in the way contractual documents are interpreted. |
| Antaios Compania Naviera S.A. v. Salen Rederierna A.B. | N/A | Yes | [1985] A.C. 191 | N/A | Cited for the principle that if detailed semantic and syntactical analysis of words in a commercial contract is going to lead to a conclusion that flouts business commonsense, it must be made to yield to business commonsense. |
| Mannai Investments Co. Ltd. v. Eagle Star Life Assurance Co. Ltd. | N/A | Yes | [1997] A.C. 749 | N/A | Cited for the principle that the parties must, for whatever reason, have used the wrong words or syntax. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Evidence Act (Cap 97, 1997 Rev Ed) | Singapore |
| Evidence Act (Cap 97, 1997 Rev Ed) s 2(2) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Angioplasty
- Estimate of Hospital Charges
- Conditions of Services/Hospital Policies
- Undertaking
- Factual Matrix
- Construction of Contract
- Unconscionability
15.2 Keywords
- contract
- hospital
- medical
- angioplasty
- estimate
- liability
- Singapore
- Court of Appeal
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Contract Law | 90 |
| Rules of construction | 70 |
| Civil Procedure | 30 |
16. Subjects
- Contract Law
- Medical Negligence
- Hospital Services
- Contractual Interpretation