Seto Wei Meng v Foo Chee Boon Edward: Negligence in Liposuction and Fat Transfer Procedure

In Seto Wei Meng v Foo Chee Boon Edward, the High Court of Singapore ruled in favor of the plaintiffs, the administrators of the estate of Yeong Soek Mun, against Dr. Foo Chee Boon Edward for negligence. The case involved a fatal liposuction and fat transfer procedure performed by Dr. Foo on Yeong Soek Mun, which resulted in her death due to pulmonary fat embolism. The plaintiffs alleged negligence in obtaining informed consent, performing the procedure, and managing the postoperative condition. The court found Dr. Foo negligent and awarded damages for the estate claim, dependency claim, and loss of inheritance claim.

1. Case Overview

1.1 Court

High Court of the Republic of Singapore

1.2 Outcome

Judgment for Plaintiffs

1.3 Case Type

Civil

1.4 Judgment Type

Judgment

1.5 Jurisdiction

Singapore

1.6 Description

The High Court found Dr. Foo negligent in a liposuction and fat transfer procedure, leading to the patient's death from pulmonary fat embolism. The court awarded damages for the estate, dependency, and loss of inheritance claims.

1.7 Decision Date

25 November 2020

2. Parties and Outcomes

Party Name	Role	Type	Outcome	Outcome Type	Counsels
Foo Chee Boon Edward	Defendant	Individual	Judgment against Defendant	Lost	Lim Min of K&L Gates Straits Law LLC Narayanan Sreenivasan of K&L Gates Straits Law LLC Sundararaj Palaniaapan of K&L Gates Straits Law LLC Gan Guo Wei of Charles Lin LLC
Seto Wei Meng	Plaintiff	Individual	Judgment for Plaintiff	Won	Kuah Boon Theng of Legal Clinic LLC Yong Shuk Lin Vanessa of Legal Clinic LLC Chain Xiao Jing Felicia of Legal Clinic LLC
Seto Mun Chap	Plaintiff	Individual	Judgment for Plaintiff	Won	Kuah Boon Theng of Legal Clinic LLC Yong Shuk Lin Vanessa of Legal Clinic LLC Chain Xiao Jing Felicia of Legal Clinic LLC
International Medical Group Holdings Pte Ltd	Defendant	Corporation	Action stayed	Stayed
TCS Medical Pte Ltd	Defendant	Corporation	Action stayed	Stayed
Singapore General Hospital Pte Ltd	Third Party	Corporation	Claim Dismissed	Dismissed	Mak Wei Munn of Allen & Gledhill LLP Teh Shi Ying of Allen & Gledhill LLP Ong Hui Fen Rachel of Allen & Gledhill LLP

3. Judges

Judge Name	Title	Delivered Judgment
Choo Han Teck	Judge	Yes

4. Counsels

Counsel Name	Organization
Lim Min	K&L Gates Straits Law LLC
Narayanan Sreenivasan	K&L Gates Straits Law LLC
Sundararaj Palaniaapan	K&L Gates Straits Law LLC
Gan Guo Wei	Charles Lin LLC
Kuah Boon Theng	Legal Clinic LLC
Yong Shuk Lin Vanessa	Legal Clinic LLC
Chain Xiao Jing Felicia	Legal Clinic LLC
Mak Wei Munn	Allen & Gledhill LLP
Teh Shi Ying	Allen & Gledhill LLP
Ong Hui Fen Rachel	Allen & Gledhill LLP

4. Facts

Mandy Yeong, 44, underwent a liposuction and fat transfer procedure performed by Dr. Foo.
Mandy Yeong had two previous liposuction procedures in 2010 and 2011.
During the procedure, Mandy Yeong's blood oxygen level dropped to 72%.
Mandy Yeong suffered a cardiovascular collapse and died due to pulmonary fat embolism.
Dr. Foo did not adequately inform Mandy Yeong of the risks associated with the procedure.
Dr. Foo delayed calling for an ambulance after Mandy Yeong's condition deteriorated.
Dr. Foo breached Specific Licensing Conditions by collecting a deposit before the stipulated seven-day period.

5. Formal Citations

Seto Wei Meng (suing as the administrator of the estateand on behalf of the dependants of Yeong Soek Mun, deceased) and anothervFoo Chee Boon Edward and others(Singapore General Hospital Pte Ltd, third party), Suit No 553 of 2016, [2020] SGHC 260

6. Timeline

Date	Event
2010-07-29	First liposuction procedure performed by Dr. Teo
2011-07-18	Second liposuction and fat transfer procedure performed by Dr. Foo
2013-05-28	Mandy Yeong consulted Dr. Foo
2013-06-14	Initial date scheduled for the third liposuction and fat transfer procedure
2013-06-28	Fatal liposuction and fat transfer procedure performed by Dr. Foo
2013-06-28	Mandy Yeong's blood oxygen level dropped to 72%
2013-06-28	Ambulance called
2013-06-28	Mandy Yeong taken to Singapore General Hospital
2013-06-28	Mandy Yeong died
2016-01-01	Suit filed
2016-10-08	Mr. Yeong passed away
2020-07-01	Trial began
2020-09-18	Judgment reserved
2020-11-26	Judgment issued

7. Legal Issues

Negligence
- Outcome: The court found Dr. Foo negligent in performing the procedure and managing the postoperative condition, leading to Mandy Yeong's death.
- Category: Substantive
- Sub-Issues:
  - Failure to obtain informed consent
  - Negligent performance of liposuction and fat transfer procedure
  - Negligent management of postoperative condition
Informed Consent
- Outcome: The court found that Dr. Foo did not adequately draw Mandy Yeong’s attention to the risk of fat embolism, as well as the increased risk of fat embolism in the case of a repeat liposuction with a fat transfer.
- Category: Substantive
Causation
- Outcome: The court found that Dr. Foo's negligence caused Mandy Yeong's death.
- Category: Substantive

8. Remedies Sought

Damages for estate claim
Damages for dependency claim
Damages for loss of inheritance claim

9. Cause of Actions

Negligence

10. Practice Areas

Personal Injury
Medical Malpractice

11. Industries

Healthcare
Cosmetic Surgery

12. Cited Cases

Case Name	Court	Affirmed	Citation	Jurisdiction	Significance
Zhu Xiu Chun (alias Myint Myint Kyi) v Rockwills Trustee Ltd (administrators of the estate of and on behalf of the dependants of Heng Ang Tee Franklin, deceased) and other appeals	Court of Appeal	Yes	[2016] 5 SLR 412	Singapore	Cited for the principle that coroner’s inquiry fees are claimable as long as the amount claimed is reasonable and proportionate.
Armstrong, Carol Ann (executrix of the estate of Peter Traynor, deceased, and on behalf of the dependents of Peter Traynor, deceased) v Quest Laboratories Pte Ltd and another and other appeals	Court of Appeal	Yes	[2020] 1 SLR 133	Singapore	Cited for the method to determine the deceased’s dependents’ reasonable expectation of pecuniary benefit.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute Name	Jurisdiction
Civil Law Act (Cap 43, 1999 Rev Ed) s 21(4)	Singapore
Private Hospitals and Medical Clinics Regulations (Cap 248, Rg 1, 2002 Rev Ed) reg 37 read with the Third Schedule	Singapore
Retirement and Re-employment Act (Cap 274A, 2012 Rev Ed)	Singapore

15. Key Terms and Keywords

15.1 Key Terms

Liposuction
Fat transfer
Pulmonary fat embolism
Negligence
Informed consent
Postoperative condition
Specific Licensing Conditions
Tumescent technique
Estate claim
Dependency claim
Loss of inheritance claim
Fulminant fat embolism

15.2 Keywords

liposuction
fat transfer
negligence
medical malpractice
pulmonary fat embolism
cosmetic surgery
Singapore
High Court

17. Areas of Law

Area Name	Relevance Score
Negligence	95
Medical Malpractice	85
Pulmonary Fat Embolism	80
Liposuction Complications	75
Personal Injury	75
Informed consent	70
Wrongful Death	60
Measure of Damages	50
Evidence	40
Contract Law	20

16. Subjects

Medical Law
Tort Law
Personal Injury
Negligence