Lee Chi Lena v Chien Chuen Chi Jeffrey: Injunction Against Property Disposal in Divorce Proceedings
In Lee Chi Lena v Chien Chuen Chi Jeffrey, the High Court of Singapore heard an appeal by the wife, Lee Chi Lena, against the District Judge's decision to refuse an injunction. The injunction sought to restrain the husband, Chien Chuen Chi Jeffrey, from disposing of a property in Shanghai pending divorce proceedings. Choo Han Teck J dismissed the wife's appeal, finding that there were sufficient other matrimonial assets to satisfy a likely division in her favor, despite the potential disposal of the Shanghai property.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Appeal dismissed with costs.
1.3 Case Type
Family
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal regarding an injunction to prevent the husband from disposing of property during divorce. The court dismissed the appeal, finding sufficient remaining matrimonial assets.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Lee Chi Lena | Plaintiff, Appellant | Individual | Appeal dismissed | Lost | |
| Chien Chuen Chi Jeffrey | Defendant, Respondent | Individual | Appeal dismissed | Won | |
| Qian Jie | Co-defendant | Individual | Appeal dismissed | Neutral |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Choo Han Teck | Judge | Yes |
4. Counsels
4. Facts
- The wife appealed against the District Judge's decision to refuse an injunction.
- The wife sought to restrain the husband from disposing of a property in Shanghai.
- The property is registered in the husband and the co-defendant’s names.
- The wife's divorce with the husband and the ancillary matters are pending.
- The judge dismissed the wife’s application on two grounds: insufficient interest and no proof of a real risk of dissipation.
- The matrimonial home in Singapore has a net value of $1.6m.
5. Formal Citations
- Lee Chi Lena v Chien Chuen Chi Jeffrey (Qian Jie, co-defendant), Divorce No 4447 of 2010 (RAS No 4 of 2011), [2011] SGHC 91
6. Timeline
| Date | Event |
|---|---|
| Divorce No 4447 of 2010 filed | |
| RAS No 4 of 2011 filed | |
| Decision Date |
7. Legal Issues
- Injunction against disposal of matrimonial assets
- Outcome: The court dismissed the appeal, finding that there were sufficient other matrimonial assets to satisfy a likely division in the wife's favor.
- Category: Substantive
- Related Cases:
- [2007] 3 SLR(R) 743
- Wife's interest in matrimonial assets
- Outcome: The court held that a wife has a sufficient interest in matrimonial assets even prior to the ancillary matters hearing.
- Category: Substantive
8. Remedies Sought
- Injunction to restrain the husband from selling, transferring or disposing of the property in Shanghai
9. Cause of Actions
- Application for Injunction
10. Practice Areas
- Divorce
- Family Litigation
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| NK v NL | High Court | Yes | [2007] 3 SLR(R) 743 | Singapore | Cited for the 'global approach' to the division of matrimonial assets. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Women’s Charter (Cap 353, 1997 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Injunction
- Matrimonial assets
- Dissipation
- Real risk of dissipation
- Global approach
- Division of matrimonial assets
- Women's Charter
15.2 Keywords
- Divorce
- Injunction
- Matrimonial Assets
- Property Disposal
- Singapore
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Matrimonial Assets | 95 |
| Division of Assets | 95 |
| Matrimonial Assets Division | 90 |
| Divorce | 90 |
| Family Law | 90 |
| Division of Property | 85 |
| Injunctions | 80 |
| Matrimonial Proceedings | 80 |
| Civil Practice | 30 |
| Accountancy Law | 20 |
16. Subjects
- Family Law
- Civil Procedure