Chiang Sing Jeong v Treasure Resort: Discovery Dispute & Shareholder Oppression

In Chiang Sing Jeong and Cafe Aquarium Pte Ltd v Treasure Resort Pte Ltd and others, the High Court of Singapore heard an appeal against an assistant registrar's order for Treasure Resort Pte Ltd to make discovery of its general ledger. The plaintiffs, Chiang Sing Jeong and Cafe Aquarium Pte Ltd, sought the documents in relation to their claim for shareholder oppression and unfair discrimination. The second, fourth, and fifth defendants, Maxz Universal Development Group Pte Ltd, Tan Boon Kian, and Poh Ban Leng, appealed the order. Justice Woo Bih Li allowed the appeal, finding the requested discovery to be a fishing expedition. The court made no order on Treasure Resort Pte Ltd's appeal.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Appeal Allowed

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Chiang Sing Jeong v Treasure Resort: Appeal over discovery order related to shareholder oppression claim. Court allowed appeal, finding discovery a fishing expedition.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Chiang Sing JeongPlaintiffIndividualAppeal DismissedLostChopra Sarbjit Singh
Cafe Aquarium Pte LtdPlaintiffCorporationAppeal DismissedLostChopra Sarbjit Singh
Treasure Resort Pte LtdDefendantCorporationNo OrderNeutral
Maxz Universal Development Group Pte LtdDefendantCorporationAppeal AllowedWonHarpreet Singh Nehal, Vanathi S
Tan Boon KianDefendantIndividualAppeal AllowedWonHarpreet Singh Nehal, Vanathi S
Poh Ban LengDefendantIndividualAppeal AllowedWonHarpreet Singh Nehal, Vanathi S
Seeto KeongDefendantIndividualNeutralNeutral
Tan Eck HongDefendantIndividualNeutralNeutralAlvin Tan

3. Judges

Judge NameTitleDelivered Judgment
Woo Bih LiJudgeYes

4. Counsels

Counsel NameOrganization
Chopra Sarbjit SinghLim & Lim
Tan Teng MuanMallal & Namazie
Kronenburg Edmund JeromeBraddell Brothers
Lye Hui XianBraddell Brothers
Harpreet Singh NehalDrew & Napier LLC
Vanathi SDrew & Napier LLC
Alvin TanWong, Thomas & Leong

4. Facts

  1. Chiang and Seeto had a joint venture agreement to incorporate Treasure to take over a property and renovate a hotel.
  2. Chiang is a registered holder of one share in Treasure and is also a director.
  3. MUDG is Seeto’s corporate vehicle and holds the majority of shares in Treasure.
  4. Roscent holds a majority stake in MUDG; Rodney is a director of Treasure and Roscent.
  5. Poh is the wife of Rodney and is also a director of Treasure.
  6. Chiang claims for various shares in Treasure and for oppression and/or unfair discrimination.
  7. Chiang sought discovery of Treasure's general ledger for certain accounts, which was the subject of the appeal.

5. Formal Citations

  1. Chiang Sing Jeong and another v Treasure Resort Pte Ltd and others, Suit No 568 of 2007 (Registrar's Appeal Nos 26 and 27 of 2010), [2010] SGHC 65

6. Timeline

DateEvent
Suit No 568 of 2007 filed
Summons No 5521 of 2009 filed
Appeal allowed

7. Legal Issues

  1. Shareholder Oppression
    • Outcome: The court did not make a ruling on the merits of the oppression claim, but the appeal concerned discovery related to this claim.
    • Category: Substantive
  2. Discovery of Documents
    • Outcome: The court held that the discovery sought was a fishing expedition and allowed the appeal against the order for discovery.
    • Category: Procedural
  3. Locus Standi
    • Outcome: The court ruled that the defendants had locus standi to appeal the discovery order, even though it was not directed at them.
    • Category: Procedural

8. Remedies Sought

  1. Shares in Treasure
  2. Discovery of Documents

9. Cause of Actions

  • Shareholder Oppression
  • Unfair Discrimination

10. Practice Areas

  • Commercial Litigation

11. Industries

  • Hospitality

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
No cited cases

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Companies ActSingapore

15. Key Terms and Keywords

15.1 Key Terms

  • Discovery
  • General Ledger
  • Shareholder Oppression
  • Unfair Discrimination
  • Locus Standi
  • Fishing Expedition

15.2 Keywords

  • discovery
  • shareholder oppression
  • company
  • singapore
  • civil procedure

16. Subjects

  • Civil Procedure
  • Company Law

17. Areas of Law

  • Civil Procedure
  • Shareholder Rights
  • Discovery