Re CNA Group Ltd: Application for Extension of Judicial Management Order

CNA Group Ltd applied for a seventh extension of its judicial management order, which was initially granted in September 2015. The High Court of Singapore, presided over by Chua Lee Ming J, dismissed the application on 5 March 2019, finding insufficient evidence that the extension would likely achieve a more advantageous realization of the company's assets, specifically its listing status. The court noted the numerous failed attempts to court potential investors and concluded that extending the order based on mere hope was not justified.

1. Case Overview

1.1 Court

High Court of the Republic of Singapore

1.2 Outcome

Application dismissed

1.3 Case Type

Insolvency

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

The High Court dismissed CNA Group Ltd's application for a seventh extension of its judicial management order, citing insufficient evidence of likely success.

1.7 Decision Date

18 March 2019

2. Parties and Outcomes

Party Name	Role	Type	Outcome	Outcome Type	Counsels
CNA Group Ltd	Applicant	Corporation	Application Dismissed	Lost	Lim Hui Li Debby of Shook Lin & Bok LLP Jason Leong of Shook Lin & Bok LLP Goh Keng Huang of Shook Lin & Bok LLP

3. Judges

Judge Name	Title	Delivered Judgment
Chua Lee Ming	Judge	Yes

4. Counsels

Counsel Name	Organization
Lim Hui Li Debby	Shook Lin & Bok LLP
Jason Leong	Shook Lin & Bok LLP
Goh Keng Huang	Shook Lin & Bok LLP

4. Facts

CNA Group Ltd was placed under judicial management on 14 September 2015.
The judicial management order was extended six times prior to this application.
The company's listing status was the only remaining asset.
The Implementation Agreement with Malaysian investors had lapsed and been terminated.
Berlitz Marine Pte Ltd withdrew from proceeding further.
The judicial manager was following up with two other potential investors.

5. Formal Citations

Re CNA Group Ltd, , [2019] SGHC 78

6. Timeline

Date	Event
1990-01-26	Company incorporated in Singapore
2005-03-01	Company listed on Singapore Exchange (SESDAQ)
2007-09-01	Company listed on Singapore Stock Exchange (Mainboard)
2015-07-13	Application filed for judicial management
2015-07-21	Interim judicial managers appointed
2015-09-14	Judicial management order made
2016-03-07	Judicial management order extended
2016-09-09	Judicial management order extended
2017-03-03	Memorandum of understanding entered with Munsang Media and Printing Group Ltd and OSC Group Pte Ltd
2017-03-09	Judicial management order extended
2017-04-01	Expressions of interest received from De Run International Resources
2017-05-01	Expressions of interest received from Treasure Capital Group
2017-07-13	Company entered into Implementation Agreement with Malaysian investors
2017-07-14	Application submitted to SGX-ST to extend deadline for Resumption Proposal
2017-09-22	Judicial management order extended
2018-01-26	Judicial manager given leave to resign
2018-03-12	Judicial management order extended
2018-04-01	Funding arrangements for Malaysian investors formalized
2018-09-19	Judicial management order extended
2018-11-28	Implementation Agreement with Malaysian investors lapsed and terminated
2019-02-22	Berlitz Marine Pte Ltd withdrew from proceeding further
2019-03-05	Application to extend judicial management order dismissed
2019-03-19	Decision issued

7. Legal Issues

Extension of Judicial Management Order
- Outcome: The court held that there was insufficient basis to justify an extension of the judicial management order.
- Category: Substantive

8. Remedies Sought

Extension of Judicial Management Order

9. Cause of Actions

No cause of actions

10. Practice Areas

Insolvency
Judicial Management

11. Industries

No industries specified

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
Companies Act (Cap 50, 2006 Rev Ed)	Singapore
Section 227B(8) of the Companies Act (Cap 50)	Singapore
Section 227B(1) of the Companies Act	Singapore
Section 227Q(1) of the Companies Act	Singapore

15. Key Terms and Keywords

15.1 Key Terms

Judicial Management Order
Extension
Listing Status
Implementation Agreement
Potential Investors
Resumption Proposal

15.2 Keywords

Judicial Management
Extension
Insolvency
Singapore
Companies Act

17. Areas of Law

Area Name	Relevance Score
Judicial Management	95
Restructuring and Dissolution	80
Company Law	75
Bankruptcy	60
Winding Up	60

16. Subjects

Judicial Management
Corporate Insolvency