UJN v UJO: Division of Matrimonial Assets, Non-Disclosure of Bonuses and Property Values

In UJN v UJO, the Court of Appeal of Singapore heard an appeal concerning the division of matrimonial assets following a divorce. The husband, UJN, appealed against the lower court's decision, contesting findings related to undisclosed bonuses from Company [J], the valuation of properties in New York and London, shares in Company [D], and the value of a property in Loyang. The court partially allowed the appeal, adjusting the pool of matrimonial assets by deducting US$1,870,000 related to the bonuses and revaluing the Loyang property at $5 million. The court dismissed the remaining grounds of appeal. The wife was ordered to pay the husband $25,000 in costs.

1. Case Overview

1.1 Court

Court of Appeal of the Republic of Singapore

1.2 Outcome

Appeal Allowed in Part

1.3 Case Type

Family

1.4 Judgment Type

Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Appeal regarding the division of matrimonial assets, focusing on undisclosed bonuses, property values, and shares. The court partially allowed the appeal, adjusting the asset pool.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
UJNAppellant, PlaintiffIndividualAppeal allowed in partPartial
UJORespondent, DefendantIndividualAppeal partially allowedPartial

3. Judges

Judge NameTitleDelivered Judgment
Judith PrakashJustice of the Court of AppealNo
Belinda Ang Saw EanJudge of the Appellate DivisionNo
Woo Bih LiJudge of the Appellate DivisionYes

4. Counsels

4. Facts

  1. The husband allegedly failed to disclose US$1,870,000 in bonuses and awards from Company [J].
  2. The husband was a joint owner of properties in New York and London.
  3. The husband allegedly failed to account for US$2.3m worth of shares in Company [D].
  4. A trading account with [H] had a balance of $367,599.68.
  5. The value of a property located at Loyang was disputed.

5. Formal Citations

  1. UJN v UJO, Civil Appeal No 172 of 2020, [2021] SGCA 39

6. Timeline

DateEvent
Divorce proceedings commenced
Interim Judgment issued
Judge delivered judgment
Husband filed an appeal
Judgment reserved
Judgment delivered

7. Legal Issues

  1. Division of Matrimonial Assets
    • Outcome: The court adjusted the pool of matrimonial assets by deducting US$1,870,000 and revaluing the Loyang property.
    • Category: Substantive
  2. Non-Disclosure of Assets
    • Outcome: The court initially drew an adverse inference against the husband for failing to disclose all his assets, but this was partially reversed on appeal.
    • Category: Substantive

8. Remedies Sought

  1. Adjustment of matrimonial asset division

9. Cause of Actions

  • No cause of actions

10. Practice Areas

  • Divorce
  • Family Law
  • Appeals

11. Industries

  • No industries specified

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

  • Matrimonial assets
  • Division of assets
  • Non-disclosure
  • Bonuses
  • Property valuation
  • Shares
  • Interim judgment

15.2 Keywords

  • matrimonial assets
  • division of assets
  • divorce
  • family law
  • Singapore
  • appeal

17. Areas of Law

16. Subjects

  • Family Law
  • Divorce
  • Asset Division