Lo Pui Sang v Mamata Kapildev Dave: En Bloc Sale of Horizon Towers - Constitutional & Good Faith Challenges
Lo Pui Sang, Quek Keng Seng, and Canterford Limited appealed the Strata Titles Board's (STB) approval of the en bloc sale of Horizon Towers to Horizon Partners Pte Ltd. The High Court, presided over by Justice Choo Han Teck, dismissed the appeals, rejecting arguments that the Land Titles (Strata) Act violated constitutional rights and that the sale was conducted in bad faith. The court found no error of law in the STB's decision.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Appeals dismissed.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal against STB's approval of Horizon Towers' en bloc sale. Court rejects constitutional challenges and bad faith claims, upholding the sale.
1.7 Decision Date
2. Parties and Outcomes
Party Name | Role | Type | Outcome | Outcome Type | Counsels |
---|---|---|---|---|---|
Lo Pui Sang | Appellant | Individual | Appeal Dismissed | Lost | |
Quek Keng Seng | Appellant | Individual | Appeal Dismissed | Lost | |
Canterford Limited | Appellant | Corporation | Appeal Dismissed | Lost | |
Mamata Kapildev Dave | Respondent | Individual | Judgment for Respondent | Won | C R Rajah, Anand Karthigesu, Burton Chen, Lalitha Rajah |
Horizon Partners Pte Ltd | Intervener | Corporation | Intervention Successful | Neutral | K Shanmugam, Ang Cheng Hock, Corina Song, William Ong, Sybil Rocha |
3. Judges
Judge Name | Title | Delivered Judgment |
---|---|---|
Choo Han Teck | Judge | Yes |
4. Counsels
Counsel Name | Organization |
---|---|
K S Rajah | Harry Elias Partnership |
Harry Elias | Harry Elias Partnership |
Philip Fong | Harry Elias Partnership |
Justin Chia | Harry Elias Partnership |
Evangeline Poh | Harry Elias Partnership |
C R Rajah | Tan, Rajah & Cheah |
Anand Karthigesu | Tan, Rajah & Cheah |
Burton Chen | Tan, Rajah & Cheah |
Lalitha Rajah | Tan, Rajah & Cheah |
K Shanmugam | Allen & Gledhill LLP |
Ang Cheng Hock | Allen & Gledhill LLP |
Corina Song | Allen & Gledhill LLP |
William Ong | Allen & Gledhill LLP |
Sybil Rocha | Allen & Gledhill LLP |
4. Facts
- Minority subsidiary proprietors appealed against the Strata Titles Board's approval of the en bloc sale.
- The majority subsidiary proprietors had signed a collective sale agreement on 11 May 2006.
- Horizon Partners Pte Ltd was granted an option to purchase Horizon Towers en bloc for $500m.
- The Strata Titles Board delivered its decision orally on 7 December 2007, approving the sale.
- A higher offer of $510m from Vineyard Holdings (HK) Ltd was not accepted by the sales committee.
- The sales committee only considered one method of distribution of sales proceeds.
5. Formal Citations
- Lo Pui Sang and Others v Mamata Kapildev Dave and Others (Horizon Partners Pte Ltd, intervener) and Other Appeals, OS 5/2008, 10/2008, 11/2008, [2008] SGHC 116
6. Timeline
Date | Event |
---|---|
Collective sale agreement signed | |
Option to purchase granted to Horizon Partners Pte Ltd | |
Option to purchase signed by Horizon Partners Pte Ltd | |
Application to Strata Titles Board for approval of sale | |
Strata Titles Board hearing | |
Original deadline for STB order | |
Deadline extended to 11 December 2007 | |
High Court remitted the matter to the STB | |
Strata Titles Board approved the sale orally | |
Strata Titles Board issued grounds of decision | |
Judgment reserved |
7. Legal Issues
- Violation of Article 9(1) of the Constitution
- Outcome: The court held that ss 84A(1) and 84B(1)(b) of the Land Titles (Strata) Act did not violate Article 9(1) of the Constitution.
- Category: Constitutional
- Violation of Article 12(1) of the Constitution
- Outcome: The court held that ss 84A(1) and 84B(1)(b) of the Land Titles (Strata) Act did not violate Article 12(1) of the Constitution.
- Category: Constitutional
- Breach of Rules of Natural Justice
- Outcome: The court found that the Strata Titles Board did not breach the rules of natural justice.
- Category: Procedural
- Transaction Made in Bad Faith
- Outcome: The court held that the transaction was made in good faith.
- Category: Substantive
- Strata Titles Board acting functus officio
- Outcome: The court held that the Strata Titles Board was not acting functus officio when it delivered its grounds of decision after giving oral decision.
- Category: Procedural
8. Remedies Sought
- Setting aside the decision of the Strata Titles Board
9. Cause of Actions
- Appeal against decision of Strata Titles Board
10. Practice Areas
- Commercial Litigation
- Real Estate Law
11. Industries
- Real Estate
12. Cited Cases
Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
---|---|---|---|---|---|
Re an Arbitration between Stringer and Riley Brothers | Queen's Bench | Yes | [1901] 1 QB 105 | England and Wales | Cited regarding the tribunal making or amending the award or an operative part of its decision. |
13. Applicable Rules
Rule Name |
---|
No applicable rules |
14. Applicable Statutes
Statute Name | Jurisdiction |
---|---|
Land Titles (Strata) Act (Cap 158, 1999 Rev Ed) s 84A(1) | Singapore |
Land Titles (Strata) Act (Cap 158, 1999 Rev Ed) s 84B(1)(b) | Singapore |
Constitution of the Republic of Singapore (1985 Rev Ed, 1999 Reprint) Art 9(1) | Singapore |
Constitution of the Republic of Singapore (1985 Rev Ed, 1999 Reprint) Art 12(1) | Singapore |
Building Maintenance and Strata Management Act 2004 (Act 47 of 2004) s 98 | Singapore |
Land Titles (Strata) Act (Cap 158, 1999 Rev Ed) s 84A(9) | Singapore |
Land Acquisition Act (Cap 152, 1985 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- En bloc sale
- Strata Titles Board
- Collective sale agreement
- Subsidiary proprietors
- Functus officio
- Good faith
- Natural justice
- Horizon Towers
15.2 Keywords
- En bloc sale
- Strata Titles Board
- Constitutional rights
- Good faith
- Horizon Towers
- Singapore
- Land Titles Act
16. Subjects
- Constitutional Law
- Strata Titles
- Real Estate
- Civil Procedure
17. Areas of Law
- Constitutional Law
- Land Law
- Strata Titles
- Collective Sales