Hendricks v Shangri-La: Hotel Liability for Lost Ring & Innkeepers Act

Bass Anne Hendricks sued Shangri-La Hotel Ltd in the High Court of Singapore, alleging the loss or theft of her valuable ring at the hotel on February 6, 2009. Judith Prakash J. dismissed the claim, finding that Hendricks failed to prove the ring was within the hotel's premises at the time of the alleged loss and that the hotel was not negligent. The court also found that even if the ring was lost at the hotel, the hotel could limit its liability to $500 under the Innkeepers' Act.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Plaintiff's claim dismissed with costs.

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

A guest sued Shangri-La Hotel for a lost diamond ring. The court dismissed the claim, finding the guest failed to prove the ring was lost at the hotel.

1.7 Decision Date

24 October 2011

2. Parties and Outcomes

Party Name	Role	Type	Outcome	Outcome Type	Counsels
Bass Anne Hendricks	Plaintiff	Individual	Claim Dismissed	Lost	Tan Chuan Thye of Stamford Law Corporation Eugene Thuraisingam of Stamford Law Corporation Mervyn Cheong Jun Ming of Stamford Law Corporation
Shangri-la Hotel Ltd	Defendant	Corporation	Judgment for Defendant	Won	Tan Hui Ying Grace of KhattarWong LLP K Anparasan of KhattarWong LLP

3. Judges

Judge Name	Title	Delivered Judgment
Judith Prakash	Judge	Yes

4. Counsels

Counsel Name	Organization
Tan Chuan Thye	Stamford Law Corporation
Eugene Thuraisingam	Stamford Law Corporation
Mervyn Cheong Jun Ming	Stamford Law Corporation
Tan Hui Ying Grace	KhattarWong LLP
K Anparasan	KhattarWong LLP

4. Facts

The plaintiff stayed at the Shangri-la Hotel in Singapore in February 2009.
The plaintiff claimed her gold and diamond ring was lost or stolen from her suite.
The plaintiff removed the ring before a massage and left it on the dressing table.
Hotel staff, including a masseuse and butler, had access to the plaintiff's suite.
The hotel conducted internal investigations and assisted the police.
The police investigation was inconclusive.

5. Formal Citations

Bass Anne Hendricks v Shangri-la Hotel Ltd, Suit No 149 of 2010, [2011] SGHC 232

6. Timeline

Date	Event
2009-02-04	Plaintiff arrived in Singapore and checked into the hotel.
2009-02-06	Plaintiff left the hotel before lunchtime.
2009-02-06	Plaintiff returned to the hotel at 6:02 pm.
2009-02-06	Masseuse and assistant fitness manager entered the suite at 6:25 pm.
2009-02-06	Assistant fitness manager left the suite at 6:26 pm.
2009-02-06	Masseuse left the suite at 7:35 pm.
2009-02-06	Butler entered the suite to deliver room service at 9:31 pm.
2009-02-06	Butler left the suite at 9:32 pm.
2009-02-06	Plaintiff realized the ring was missing around 10:00 pm.
2009-02-06	Assistant Manager arrived at the suite at 10:14 pm.
2009-02-06	Plaintiff informed Assistant Manager she could not find the ring at 10:45 pm.
2009-02-07	Hotel staff conducted a search of the suite in the plaintiff's absence.
2009-02-07	Police arrived at 7:15 pm and interviewed the plaintiff and hotel staff.
2009-02-10	Hotel concluded its internal investigation.
2010-03-03	Plaintiff filed a writ of summons.
2011-10-25	Judgment reserved.

7. Legal Issues

Liability of Innkeeper for Loss of Guest's Property
- Outcome: The court found that the plaintiff failed to prove the ring was within the hotel's premises and that the hotel was not negligent.
- Category: Substantive
- Sub-Issues:
  - Breach of duty of care
  - Application of Innkeepers' Act
  - Guest negligence
Guest's Negligence
- Outcome: The court found that the plaintiff was negligent in not taking reasonable steps to safeguard her ring.
- Category: Substantive
- Sub-Issues:
  - Failure to secure valuables
  - Reasonable care of belongings
Statutory Limitation of Liability
- Outcome: The court found that even if the hotel was liable, it could limit its liability to $500 under the Innkeepers' Act.
- Category: Substantive
- Sub-Issues:
  - Compliance with Innkeepers' Act
  - Display of notice

8. Remedies Sought

Monetary Damages

9. Cause of Actions

Negligence
Breach of Contract
Conversion

10. Practice Areas

Commercial Litigation

11. Industries

Hospitality

12. Cited Cases

Case Name	Court	Affirmed	Citation	Jurisdiction	Significance
Fleming John C v Sealion Hotels Ltd	Singapore Law Reports	Yes	[1987] SLR(R) 325	Singapore	Cited for the common law principle that a hotel proprietor is strictly liable as an insurer for the property of guests lost or stolen within the hotel.
Armistead v Wilde	Queen's Bench	Yes	[1851] 17 QB 261	England and Wales	Cited for the principle that an innkeeper can escape liability if the loss is due to the guest's negligence.
Jones v Jackson	Not Available	Yes	(1873) 29 LT 399	England and Wales	Cited to illustrate a situation where a guest's negligence prevented recovery for loss of property at an inn, but distinguished on its facts.
Oppenheim v The White Lion Hotel	Court of Common Pleas	Yes	(1871) LR 6 CP 515	England and Wales	Cited to support the argument that a guest's negligence in securing their belongings can relieve an innkeeper of liability.
Whitehouse v R&W Pickett	House of Lords	Yes	[1908] 1 AC 357	United Kingdom	Cited for the principle that negligence cannot be established by mere surmise about the manner of loss.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute Name	Jurisdiction
Innkeepers’ Act (Cap 139, 1985 Rev Ed)	Singapore
Innkeepers’ Act (Cap 139, 1985 Rev Ed)	Singapore

15. Key Terms and Keywords

15.1 Key Terms

Hospitium
Innkeeper
Strict Liability
Negligence
Innkeepers' Act
Limitation of Liability
Conversion

15.2 Keywords

Hotel
Ring
Loss
Negligence
Innkeeper
Liability
Singapore

17. Areas of Law

Area Name	Relevance Score
Hospitality Law	75
Evidence	40
Contract Law	30
Personal Injury	20
Estoppel	10

16. Subjects

Hotel Liability
Loss of Property
Guest Negligence