Wong Chong Hui v Lim Siong Hoe Lawrence: Unilateral Mistake in Contract Law

In Wong Chong Hui and Heng Hong Development Pte Ltd v Lim Siong Hoe Lawrence, the High Court of Singapore heard an appeal regarding a road accident claim. The respondent, Lim Siong Hoe Lawrence, sought damages for personal injury after signing a discharge voucher (DV) that the appellants, Wong Chong Hui and Heng Hong Development Pte Ltd, argued released them from all claims. The High Court allowed the appeal, finding that the DV was valid and discharged all claims, including personal injury, against the appellants. The court found that the respondent understood the terms of the DV and that NTUC Income did not have actual knowledge of the respondent’s mistake.

1. Case Overview

1.1 Court

High Court of the Republic of Singapore

1.2 Outcome

Appeal Allowed

1.3 Case Type

Civil

1.4 Judgment Type

Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Appeal regarding a road accident claim. The court held that a discharge voucher signed by the respondent fully discharged all claims, including personal injury, against the appellants.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Wong Chong HuiAppellantIndividualAppeal AllowedWon
Heng Hong Development Pte LtdAppellantCorporationAppeal AllowedWon
Lim Siong Hoe LawrenceRespondentIndividualAppeal DismissedLost

3. Judges

Judge NameTitleDelivered Judgment
Choo Han TeckJudgeYes

4. Counsels

Counsel NameOrganization
Tan Seng Chew RichardTan Chin Hoe & Co
Peh Siqi, MichelleTan Chin Hoe & Co
Ramesh s/o VarathappanTito Isaac & Co LLP

4. Facts

  1. Respondent was involved in a seven-vehicle chain collision.
  2. Respondent's vehicle was hit by the second appellant's vehicle.
  3. Respondent sent his vehicle to the Workshop for repairs.
  4. Workshop lodged a claim with NTUC Income for $9,052.20.
  5. Respondent signed a discharge voucher after the claim was settled.
  6. Respondent later claimed for personal injury, including pain and suffering.
  7. NTUC Income rejected the claim based on the discharge voucher.

5. Formal Citations

  1. Wong Chong Hui and another v Lim Siong Hoe Lawrence, HC/District Court Appeal No 29 of 2018, [2019] SGHC 85

6. Timeline

DateEvent
Road accident occurred involving the respondent.
Respondent consulted Dr Tan and underwent MRI.
Respondent filed an accident report.
Workshop lodged a claim with NTUC Income.
Respondent signed a discharge voucher.
Parkway East Hospital issued a physiotherapy report.
Dr Tan issued a specialist medical report.
Respondent sent a letter of demand to the first appellant.
NTUC Income rejected the respondent’s claim.
Respondent commenced Magistrate’s Court Suit No 19075 of 2014.
Appellants appealed against Lee DJ’s decision in MC 19075.
Judgment reserved.
Judgment issued.

7. Legal Issues

  1. Unilateral Mistake
    • Outcome: The court held that the discharge voucher was not void on the ground of unilateral mistake.
    • Category: Substantive
    • Sub-Issues:
      • Actual knowledge of mistake
      • Fundamental mistake as to terms
    • Related Cases:
      • [2018] 2 SLR 110
      • [2005] 1 SLR(R) 502
  2. Discharge Voucher
    • Outcome: The court held that the discharge voucher fully discharged all claims that the respondent had against NTUC Income.
    • Category: Substantive
    • Related Cases:
      • [2012] 3 SLR 172

8. Remedies Sought

  1. Monetary Damages

9. Cause of Actions

  • Negligence
  • Breach of Contract

10. Practice Areas

  • Commercial Litigation

11. Industries

  • Insurance

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Ter Yin Wei v Lim Leet FangHigh CourtYes[2012] 3 SLR 172SingaporeCited to distinguish the discharge voucher from a mere receipt.
Broadley Construction Pte Ltd v Alacran Design Pte LtdCourt of AppealYes[2018] 2 SLR 110SingaporeCited for the requirements to render a contract void on the common law ground of unilateral mistake.
Chwee Kin Keong and others v Digilandmall.com Pte LtdHigh CourtYes[2005] 1 SLR(R) 502SingaporeCited for the requirements to render a contract void on the common law ground of unilateral mistake.

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

  • Discharge Voucher
  • Unilateral Mistake
  • Personal Injury Claim
  • Property Damage Claim
  • Accident Report
  • Wilful Blindness

15.2 Keywords

  • Discharge Voucher
  • Unilateral Mistake
  • Road Accident
  • Personal Injury
  • Contract Law

17. Areas of Law

Area NameRelevance Score
Unilateral mistake85
Mistake80
Contract Law75
Discharge Voucher70
Personal Injury60
Road Traffic Accident Law55
Automobile Accidents50
Civil Procedure30
Evidence Law25

16. Subjects

  • Contract Law
  • Tort Law
  • Motor Vehicle Accidents