Wang Sam Lin v Burridge Steven Harold: Trespass, Negligence, and Breach of Contract in Horse Training Dispute
Dr. Wang Sam Lin sued Steven Harold Burridge (trading as Steven Burridge Racing Stables) in the High Court of Singapore on 6 November 2009, alleging trespass, negligence, and breach of contract related to the training of his racehorse, King and King. Wang claimed Burridge administered a steroid injection without his consent, preventing the horse from racing. The court (Judith Prakash J) found Burridge liable for trespass but awarded only nominal damages of $100, as Wang failed to prove actual loss due to the horse's pre-existing condition. Burridge's counterclaim was resolved separately.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Judgment for the plaintiff; nominal damages awarded.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Horse owner Wang Sam Lin sued trainer Steven Burridge for trespass, negligence, and breach of contract. The court found trespass but awarded only nominal damages.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Wang Sam Lin | Plaintiff | Individual | Judgment for Plaintiff | Won | S Gunaseelan |
| Burridge Steven Harold (trading as Steven Burridge Racing Stables) | Defendant | Individual | Costs Awarded | Other | S Karthikeyan |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Judith Prakash | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| S Gunaseelan | S Gunaseelan & Partners |
| S Karthikeyan | Toh Tan LLP |
4. Facts
- Plaintiff engaged defendant to train racehorses, including King and King, in October 2005.
- The parties did not enter into a written training contract; their agreement was oral.
- King and King won six races in 2006 but fell during a race on 29 October 2006.
- On 28 October 2007, King and King finished poorly, leading the plaintiff to consider transferring the horse.
- On 29 October 2007, the plaintiff decided to transfer King and King to another trainer, Desmond Koh.
- The defendant administered a steroid injection to King and King on 29 October 2007, without the plaintiff's knowledge.
- The steroid injection made King and King ineligible to race for 40 days.
5. Formal Citations
- Wang Sam Lin v Burridge Steven Harold (trading as Steven Burridge Racing Stables), Suit 718/2007, [2009] SGHC 252
6. Timeline
| Date | Event |
|---|---|
| Plaintiff engaged the defendant to train racehorses. | |
| King and King first raced and came in first. | |
| King and King fell during a race. | |
| King and King came in second in a race. | |
| King and King finished eleventh out of thirteen horses in a race. | |
| Plaintiff decided to transfer King and King to another trainer. | |
| Defendant withdrew King and King from the Singapore Gold Cup race. | |
| Defendant administered a steroid injection to King and King. | |
| King and King was moved to Desmond Koh's premises. | |
| Urine samples of the horses were sent to be tested. | |
| Inquiry regarding the circumstances surrounding the stable transfer and treatment of King and King commenced. | |
| Inquiry regarding the circumstances surrounding the stable transfer and treatment of King and King continued. | |
| Inquiry regarding the circumstances surrounding the stable transfer and treatment of King and King concluded. | |
| Judgment issued. |
7. Legal Issues
- Trespass to Goods
- Outcome: The court found that the defendant committed trespass by administering the steroid injection without the plaintiff's consent.
- Category: Substantive
- Sub-Issues:
- Unpermitted contact with chattel
- Wrongful physical interference
- Related Cases:
- [1993] 1 SLR 849
- Breach of Contract
- Outcome: The court found that the contract had been terminated by the time the injection was administered, and therefore there was no breach of contract.
- Category: Substantive
- Negligence
- Outcome: The court found no cause of action for negligence, as the defendant was not careless in the care of the horse.
- Category: Substantive
- Damages for Loss of a Chance
- Outcome: The court held that the plaintiff did not suffer any real loss because the horse was unfit to race, making the chance of winning prize money speculative.
- Category: Substantive
- Related Cases:
- [1911] 2 KB 786
- [2005] 1 SLR 661
- Causation
- Outcome: The court determined that the injection was an effective cause of the horse's inability to race, but the horse's pre-existing condition meant the plaintiff suffered no real loss.
- Category: Substantive
- Related Cases:
- [2007] 4 SLR 460
8. Remedies Sought
- Monetary Damages
9. Cause of Actions
- Trespass to Goods
- Negligence
- Breach of Contract
10. Practice Areas
- General Litigation
11. Industries
- Horse Racing
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| The Kota Bakti | Court of Appeal | Yes | [1993] 1 SLR 849 | Singapore | Cited to emphasize that trespass to goods is a wrongful physical interference. |
| Chaplin v Hicks | King's Bench | Yes | [1911] 2 KB 786 | England and Wales | Cited as the seminal case on loss of a chance as a head of damages. |
| Asia Hotel Investments Ltd v Starwood Asia Pacific Management Pte Ltd | Court of Appeal | Yes | [2005] 1 SLR 661 | Singapore | Applied Chaplin v Hicks locally regarding loss of chance damages. |
| JSI Shipping (S) Pte Ltd v Teofoongwonglcong (a firm) | Court of Appeal | No | [2007] 4 SLR 460 | Singapore | Cited regarding the 'but for' test of causation and the concept of 'effective cause'. |
| Helen Palsgraf v The Long Island Railroad Company | New York Court of Appeals | No | (1928) 248 NY 339 | United States | Cited to illustrate the elusiveness of the concept of 'proximate cause'. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Rule of Racing 152(3) of the MRA Rules | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Horse Training
- Steroid Injection
- Trespass
- Negligence
- Breach of Contract
- Loss of a Chance
- MRA Rules
- Singapore Gold Cup
- Anabolic Steroid
- Withholding Period
15.2 Keywords
- horse racing
- trespass
- negligence
- breach of contract
- steroid injection
- damages
- Singapore
16. Subjects
- Tort Law
- Contract Law
- Sports Law
- Horse Racing
17. Areas of Law
- Tort
- Contract Law
- Horse Racing Law