World Fuel Services v Xie Sheng Guo: Restraint of Trade and Confidentiality in Aviation Oil Supply

In World Fuel Services (Singapore) Pte Ltd v Xie Sheng Guo, the High Court of Singapore addressed the enforceability of a restraint of trade clause. World Fuel Services sought to prevent its former employee, Xie Sheng Guo, from joining China Aviation Oil (Singapore) Corporation Ltd (CAO SG), a competitor, arguing that Xie possessed confidential pricing information. The court allowed the plaintiff's application, enforcing the restraint of trade clause and preventing Xie from commencing employment with CAO SG.

1. Case Overview

1.1 Court

High Court of the Republic of Singapore

1.2 Outcome

Plaintiff's application allowed.

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

The High Court enforced a restraint of trade clause, preventing Xie Sheng Guo from joining a competitor due to his knowledge of confidential pricing information in the aviation oil industry.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
World Fuel Services (Singapore) Pte LtdPlaintiffCorporationApplication allowedWon
Xie Sheng GuoDefendantIndividualApplication dismissed against defendantLost

3. Judges

Judge NameTitleDelivered Judgment
Choo Han TeckJudgeYes

4. Counsels

Counsel NameOrganization
Lee PingShook Lin & Bok LLP
Swah Yeqin ShirinShook Lin & Bok LLP
Benedict TeongTan Rajah & Cheah
Megan ChiaTan Rajah & Cheah

4. Facts

  1. The plaintiff supplies marine and aviation oil in Asia.
  2. The defendant negotiated prices of aviation oil and entered into supply contracts for the plaintiff.
  3. The defendant resigned and intended to join China Aviation Oil (Singapore) Corporation Ltd (CAO SG).
  4. The Employment Contract contained a six-month restraint of trade clause.
  5. The plaintiff's revenue may lose up to US$40m a year.
  6. The defendant had contacts with the plaintiff's suppliers in China and knew the prices.
  7. CAO SG and its subsidiaries would tender for aviation oil contracts alongside the plaintiff.

5. Formal Citations

  1. World Fuel Services (Singapore) Pte Ltd v Xie Sheng Guo, , [2019] SGHC 54
  2. World Fuel Services (Singapore) Pte Ltd v Xie Sheng Guo, 63 of 2019, HC/Suit No 63 of 2019

6. Timeline

DateEvent
Employment Contract dated
Defendant tendered his resignation
Plaintiff filed application to enjoin the defendant from commencing employment under CAO SG
Defendant's last day of work
Defendant intended to join CAO SG
Judgment issued

7. Legal Issues

  1. Enforceability of Restraint of Trade Clause
    • Outcome: The court held that the restraint of trade clause was enforceable in this case.
    • Category: Substantive
  2. Protection of Confidential Information
    • Outcome: The court found that the defendant possessed confidential information that needed protection.
    • Category: Substantive

8. Remedies Sought

  1. Injunctive Relief

9. Cause of Actions

  • Breach of Contract

10. Practice Areas

  • Commercial Litigation

11. Industries

  • Oil and Gas
  • Aviation

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
No cited cases

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
No applicable statutes

15. Key Terms and Keywords

15.1 Key Terms

  • Restraint of Trade
  • Confidential Information
  • Aviation Oil
  • Garden Leave
  • Employment Contract
  • Legitimate Proprietary Interest

15.2 Keywords

  • Restraint of trade
  • Confidential information
  • Aviation oil
  • Singapore
  • Employment contract

17. Areas of Law

Area NameRelevance Score
Contract Law90
Restraint of Trade85
Illegality and public policy75
Breach of Confidence70
Employment Law50
Anton Piller Orders30

16. Subjects

  • Contract Law
  • Employment Law
  • Competition Law