UJF v UJG: Division of Matrimonial Assets After Short Marriage

In the divorce proceedings between UJF (Wife) and UJG (Husband) in the Family Justice Courts of the Republic of Singapore, the court addressed the division of matrimonial assets following a relatively short marriage. The court considered the direct and indirect contributions of both parties, the length of the marriage, and the nature of the assets. The court ordered a division of the matrimonial assets, allocating 60% to the Husband and 40% to the Wife, and dismissed the Wife's claim for maintenance.

1. Case Overview

1.1 Court

Family Justice Courts of the Republic of Singapore

1.2 Outcome

Division of matrimonial assets ordered, with 60% to the Husband and 40% to the Wife. Wife's claim for maintenance dismissed.

1.3 Case Type

Family

1.4 Judgment Type

Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Division of matrimonial assets after a short marriage. The court considered direct and indirect contributions to determine a just and equitable division.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
UJFPlaintiffIndividualDivision of matrimonial assetsPartial
UJGDefendantIndividualDivision of matrimonial assetsPartial

3. Judges

Judge NameTitleDelivered Judgment
Aedit AbdullahJudgeYes

4. Counsels

4. Facts

  1. The parties cohabited for about ten years before marrying.
  2. The marriage lasted just under four years.
  3. The Husband was about 70 years old and the Wife was about 51 years old at the time of the proceedings.
  4. The Husband had been married twice before and has four children from those marriages.
  5. The Wife has three children from a previous marriage.
  6. The Wife was involved in various businesses run by the Husband.
  7. Various properties were purchased by the Wife before and during the marriage.
  8. The Husband commenced a civil claim alleging beneficial interest in the properties purchased by the Wife, which was later discontinued.

5. Formal Citations

  1. UJF v UJG, Divorce (Transferred) No 1342 of 2013, [2018] SGHCF 1

6. Timeline

DateEvent
Parties married
Statement of Particulars (Divorce) (Amendment No. 1) filed
Interim judgment granted
Husband’s Core Bundle of Documents filed
Hearing commenced
Hearing continued
Certified Transcript date
Hearing continued
Wife’s Written Submissions for Division dated
Hearing continued
Judgment reserved

7. Legal Issues

  1. Division of Matrimonial Assets
    • Outcome: The court determined the division of matrimonial assets based on a ratio of 60% to the Husband and 40% to the Wife, considering direct and indirect contributions.
    • Category: Substantive
    • Sub-Issues:
      • Direct contributions
      • Indirect contributions
      • Valuation of assets
      • Classification of assets
  2. Maintenance for Former Wife
    • Outcome: The court dismissed the Wife's claim for maintenance, considering the significant pool of matrimonial assets awarded to her and the short duration of the marriage.
    • Category: Substantive

8. Remedies Sought

  1. Division of Matrimonial Assets
  2. Maintenance for the Wife

9. Cause of Actions

  • Divorce
  • Division of Matrimonial Assets
  • Claim for Maintenance

10. Practice Areas

  • Divorce
  • Family Law
  • Asset Division

11. Industries

  • No industries specified

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
ANJ v ANKCourt of AppealYes[2015] 4 SLR 1043SingaporeCited as the controlling authority on the structured approach to the determination of division of matrimonial assets.
TNL v TNK and another appeal and another matterCourt of AppealYes[2017] 1 SLR 609SingaporeCited for clarifying that the approach in ANJ v ANK should not be applied to marriages where only one spouse earns income.
NK v NLUnknownYes[2007] 3 SLR(R) 743SingaporeCited for the classification methodology in determining the respective contributions and divide the various properties into separate categories.
TNC v TNDUnknownYes[2016] 3 SLR 1172SingaporeCited for the approach that in respect of assets acquired pre-marriage which have been improved, it is only the increase in value from improvement that is subject to division.
BHN v BHOHigh CourtYes[2013] SGHC 91SingaporeCited for the principle that assets acquired by payments and contributions after marriage count as acquisition and are part of the matrimonial pool.
THL v THMHigh CourtYes[2015] SGHCF 11SingaporeCited for the principle that assets acquired by payments and contributions after marriage count as acquisition and are part of the matrimonial pool.
Ting Siew May v Boon Lay Choo and anotherCourt of AppealYes[2014] 3 SLR 609SingaporeCited for the proposition that where a contract is entered into with the object of committing an illegal act, the response would be proportionate to the illegality.
Ochroid Trading Ltd and another v Chua Siok Lui (trading as VIE Import & Export) and anotherCourt of AppealYes[2018] SGCA 5SingaporeCited for the principle that the proportionality analysis is only relevant where the contract is not unlawful per se but entered into with the object of committing an illegal act.
Chan Tin Sun v Fong Quay SimCourt of AppealYes[2015] 2 SLR 195SingaporeCited for the law on drawing adverse inferences.
Koh Bee Choo v Choo Chai HuahSingapore Court of AppealYes[2007] SGCA 21SingaporeCited for the requirements to draw an adverse inference.
TDT v TDS and another appeal and another matterUnknownYes[2016] 4 SLR 145SingaporeCited for the wife's contributions towards the husband's work.
ATE v ATDSingapore Court of AppealYes[2016] SGCA 2SingaporeCited for the principle that the court’s power to order maintenance is supplementary to its power to divide matrimonial assets.
Ong Boon Huat Samuel v Chan Mei Lan KristineUnknownYes[2007] 2 SLR(R) 729SingaporeCited for the principle that indirect contributions usually play a de minimis role in short, childless marriages.
Yeo Chong Lin v Tay Ang Choo NancyUnknownYes[2011] 2 SLR 1157SingaporeCited for the principle that if the pool of assets available for division is extraordinarily large and all of that was accrued by one party’s exceptional efforts, direct contributions are likely to command greater weight as against indirect contributions.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Women’s Charter (Cap 353, 2009 Rev Ed)Singapore
s 112 of the Women’s CharterSingapore
s 112(10)(a)(i) of the Women’s CharterSingapore
s 112(10)(a)(ii) of the Women’s CharterSingapore
s 112(10)(b) of the Women’s CharterSingapore
s 112(2)(f) of the Women’s CharterSingapore
s 114(2) of the Women’s CharterSingapore
s 114(1) of the Women’s CharterSingapore
s 116(g) of the Evidence Act (Cap 97, 1997 Rev Ed)Singapore
s 340(1) of the Companies Act (Cap 50, 2006 Rev Ed)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Matrimonial assets
  • Direct contributions
  • Indirect contributions
  • Funds Pool
  • Matrimonial home
  • Division of property
  • Women's Charter
  • Civil Claim
  • Businesses
  • CPF moneys

15.2 Keywords

  • Divorce
  • Matrimonial Assets
  • Division of Assets
  • Family Law
  • Singapore
  • Maintenance
  • Property
  • Financial Contributions

17. Areas of Law

Area NameRelevance Score
Family Law95
Matrimonial Assets95
Divorce90
Maintenance90

16. Subjects

  • Family Law
  • Divorce
  • Matrimonial Assets
  • Division of Assets
  • Maintenance