Union Concept Manufacturers v Rhythme Technology: Negligence Claim for Fire Damage Due to Faulty Fire Hose Reel
Union Concept Manufacturers Pte Ltd and P & K Services Pte Ltd sued Rhythme Technology Pte Ltd in the High Court of Singapore, alleging negligence in the maintenance of a fire hose reel, which purportedly contributed to fire damage at their premises. The fire originated from a lit cigarette igniting flammable materials outside their warehouse. Choo Han Teck J dismissed the claim, finding that Rhythme Technology did not breach its duty of care and that, even if it had, the breach did not cause the plaintiffs' losses. The court determined that the rapid spread of the fire, fueled by combustible materials and strong winds, would not have been prevented by a functioning fire hose reel.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Plaintiff's claim dismissed.
1.3 Case Type
Civil
1.4 Judgment Type
Judgment
1.5 Jurisdiction
Singapore
1.6 Description
Union Concept Manufacturers sued Rhythme Technology for negligence, alleging a faulty fire hose reel contributed to fire damage. The court dismissed the claim, finding no breach of duty or causation.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Union Concept Manufacturers Pte Ltd | Plaintiff | Corporation | Claim Dismissed | Lost | M Ramasamy, N K Rajarh, Shelley Lim Lei-Yee |
| P & K Services Pte Ltd | Plaintiff | Corporation | Claim Dismissed | Lost | M Ramasamy, N K Rajarh, Shelley Lim Lei-Yee |
| Rhythme Technology Pte Ltd | Defendant | Corporation | Judgment for Defendant | Won | Renganathan Nandakumar, Oon Pei Gan, Simren Kaur |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Choo Han Teck | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| M Ramasamy | M Rama Law Corporation |
| N K Rajarh | M Rama Law Corporation |
| Shelley Lim Lei-Yee | M Rama Law Corporation |
| Renganathan Nandakumar | RHTLaw Taylor Wessing LLP |
| Oon Pei Gan | RHTLaw Taylor Wessing LLP |
| Simren Kaur | RHTLaw Taylor Wessing LLP |
4. Facts
- A lit cigarette ignited flammable polystyrene foam packing material outside a warehouse.
- The fire spread rapidly due to the flammable materials and strong winds.
- The plaintiffs claimed the defendant's negligence in maintaining the fire hose reel system contributed to the damage.
- The defendant's employees conducted a physical test on the fire hose reel nearest to the plaintiffs’ premises on 17 September 2009.
- The plaintiffs' key witnesses who were present on the day of the incident and had attempted to use the fire hose did not appear in court to give evidence.
- The plaintiffs had stacked large amounts of highly combustible packing material outside their warehouse which posed a high fire risk.
5. Formal Citations
- Union Concept Manufacturers Pte Ltd and another v Rhythme Technology Pte Ltd, Suit No 924 of 2012, [2015] SGHC 121
6. Timeline
| Date | Event |
|---|---|
| Fire occurred at Block 2019 Bukit Batok Street 23 | |
| Defendant's employees carried out a physical test on the fire hose reel | |
| Suit filed (Suit No 924 of 2012) | |
| Judgment reserved |
7. Legal Issues
- Breach of Duty of Care
- Outcome: The court found that the defendant did owe a duty of care to the plaintiffs, but did not breach that duty.
- Category: Substantive
- Causation
- Outcome: The court found that even if the defendant had breached its duty of care, the breach did not cause the plaintiffs' loss and damage.
- Category: Substantive
8. Remedies Sought
- Monetary Damages
9. Cause of Actions
- Negligence
10. Practice Areas
- Commercial Litigation
11. Industries
- Construction
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 |
|---|---|
| No applicable statutes | |
15. Key Terms and Keywords
15.1 Key Terms
- Fire hose reel
- Duty of care
- Negligence
- Causation
- Fire damage
- Polystyrene foam
- Flammable materials
15.2 Keywords
- Negligence
- Fire
- Hose reel
- Maintenance
- Singapore
- High Court
16. Subjects
- Negligence
- Fire Safety
- Maintenance
17. Areas of Law
- Negligence
- Tort Law
- Contract Law