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 Court1.2 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 Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Tan Boon Kian | Defendant | Individual | Appeal Allowed | Won | |
| Chiang Sing Jeong | Plaintiff | Individual | Appeal Dismissed | Lost | |
| Tan Eck Hong | Defendant | Individual | Neutral | Neutral | |
| Maxz Universal Development Group Pte Ltd | Defendant | Corporation | Appeal Allowed | Won | |
| Treasure Resort Pte Ltd | Defendant | Corporation | No Order | Neutral | |
| Seeto Keong | Defendant | Individual | Neutral | Neutral | |
| Poh Ban Leng | Defendant | Individual | Appeal Allowed | Won | |
| Café Aquarium Pte Ltd | Plaintiff | Corporation | Appeal Dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Woo Bih Li | Judge | Yes |
4. Counsels
4. Facts
- Chiang and Seeto had a joint venture agreement to incorporate Treasure to take over a property and renovate a hotel.
- Chiang is a registered holder of one share in Treasure and is also a director.
- MUDG is Seeto’s corporate vehicle and holds the majority of shares in Treasure.
- Roscent holds a majority stake in MUDG; Rodney is a director of Treasure and Roscent.
- Poh is the wife of Rodney and is also a director of Treasure.
- Chiang claims for various shares in Treasure and for oppression and/or unfair discrimination.
- Chiang sought discovery of Treasure's general ledger for certain accounts, which was the subject of the appeal.
5. Formal Citations
- 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
| Date | Event |
|---|---|
| Suit No 568 of 2007 filed | |
| Summons No 5521 of 2009 filed | |
| Appeal allowed |
7. Legal Issues
- 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
- 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
- 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
- Shares in Treasure
- Discovery of Documents
9. Cause of Actions
- Shareholder Oppression
- Unfair Discrimination
10. Practice Areas
- Commercial Litigation
11. Industries
- Hospitality
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| No cited cases | |||||
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Companies Act | Singapore |
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
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Minority Oppression | 85 |
| Company Law | 70 |
| Commercial Disputes | 60 |
| Disclosure of documents | 50 |
| Litigation | 40 |
16. Subjects
- Civil Procedure
- Company Law