VPH v VPI: Division of Matrimonial Assets and Wife's Maintenance Post-Divorce

In VPH v VPI [2021] SGHCF 22, the High Court (Family Division) heard an appeal by the husband, VPH, against the District Judge's decision regarding the division of matrimonial assets and maintenance to the wife, VPI, following their divorce. The court allowed the husband's appeal in part, adjusting the amount of CPF moneys the wife was entitled to, but upheld the District Judge's order for a lump sum maintenance payment of $60,000 to the wife. The court applied the ANJ structured approach to divide the matrimonial assets.

1. Case Overview

1.1 Court

Family Justice Courts of the Republic of Singapore

1.2 Outcome

Appeal allowed in part.

1.3 Case Type

Family

1.4 Judgment Type

Oral Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Appeal concerning division of matrimonial assets and wife's maintenance. Court adjusted asset division and upheld lump sum maintenance for the wife.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
VPHAppellantIndividualAppeal allowed in partPartial
VPIRespondentIndividualLump sum maintenance of $60,000 to remainNeutral

3. Judges

Judge NameTitleDelivered Judgment
Mavis Chionh Sze ChyiJudge of the High CourtYes

4. Counsels

Counsel NameOrganization
Foo Soon YienBR Law Corporation
Kong Shin Ying BrendaBR Law Corporation
Leong Kit Ying MelissaBayfront Law LLC

4. Facts

  1. The husband and wife were married on 11 November 2007 and separated in February 2017.
  2. The husband filed for divorce on 15 October 2018, and the wife filed a defence and counterclaim on 7 November 2018.
  3. The husband is an airline captain, and the wife is a customer relationship coordinator.
  4. The husband's income was affected by the COVID-19 pandemic, but he still had a relatively comfortable income.
  5. The wife purchased a property at Grandeur Park Residences during the marriage.
  6. The Flora Drive property was the matrimonial home.
  7. The wife was gainfully employed for a considerable part of the marriage.

5. Formal Citations

  1. VPH v VPI, District Court Appeal No 111 of 2020, [2021] SGHCF 22
  2. VPH v VPI, , [2021] SGFC 17

6. Timeline

DateEvent
Husband and wife were married.
Parties began living separately.
Husband filed a writ for divorce.
Wife filed a defence and counterclaim.
Interim judgment granted.
District Judge made orders concerning the division of matrimonial assets and maintenance.
Application to adduce fresh evidence allowed.
Judgment reserved.
Oral judgment.
Husband to pay first maintenance installment.
Husband to pay second maintenance installment.

7. Legal Issues

  1. Division of Matrimonial Assets
    • Outcome: The court adjusted the division of matrimonial assets, awarding the husband 67.5% and the wife 32.5% of the total pool.
    • Category: Substantive
    • Sub-Issues:
      • Valuation of assets
      • Direct contributions
      • Indirect contributions
      • Adverse inferences
  2. Maintenance for Wife
    • Outcome: The court upheld the District Judge's order for a lump sum maintenance of $60,000 to be paid by the husband to the wife.
    • Category: Substantive

8. Remedies Sought

  1. Division of Matrimonial Assets
  2. Maintenance for Wife

9. Cause of Actions

  • Divorce
  • Division of Matrimonial Assets
  • Maintenance

10. Practice Areas

  • Divorce
  • Family Law
  • Matrimonial Asset Division
  • Maintenance

11. Industries

  • Aviation

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Lock Yeng Fun v Chua Hock ChyeCourt of AppealYes[2007] 3 SLR(R) 520SingaporeCited to distinguish the present case based on the husband's earning capacity and lack of disabilities, unlike the respondent in Lock Yeng Fun.
ANJ v ANKCourt of AppealYes[2015] 4 SLR 1043SingaporeCited for the structured approach to dividing matrimonial assets in dual-income marriages.
TNL v TNK and another appeal and another matterCourt of AppealYes[2017] 1 SLR 609SingaporeCited to define dual-income marriage.
NK v NLN/AYes[2007] 3 SLR(R) 743SingaporeCited for the global assessment methodology for dividing matrimonial assets.
USB v USA and another appealCourt of AppealYes[2020] 2 SLR 588SingaporeCited to define matrimonial home.
USA v USBHigh CourtYes[2020] 4 SLR 288SingaporeCited regarding the inclusion of pre-marriage properties in the asset pool, but distinguished as it did not concern the matrimonial home.
UYP v UYQN/AYes[2020] 3 SLR 683SingaporeCited regarding the commingling of assets.
VJR v VJS and another matterN/AYes[2021] SGHCF 10SingaporeCited regarding the commingling of assets.
UTS v UTTN/AYes[2019] SGHCF 8SingaporeCited regarding the valuation of insurance policies.
UZN v UZMCourt of AppealYes[2021] 1 SLR 426SingaporeCited for the principles on drawing adverse inferences.
BPC v BPB and another appealN/AYes[2019] 1 SLR 608SingaporeCited for the principles on drawing adverse inferences.
TNC v TNDN/AYes[2016] 3 SLR 1172SingaporeCited regarding the relationship between division of matrimonial assets and maintenance.
TND v TNC and another appealCourt of AppealYes[2017] SGCA 34SingaporeCited regarding the relationship between division of matrimonial assets and maintenance.
Oh Choon v Lee Siew LinCourt of AppealYes[2014] 1 SLR 629SingaporeCited regarding the relationship between division of matrimonial assets and maintenance.
Lee Siew Lin v Oh ChoonHigh CourtYes[2013] SGHC 25SingaporeCited regarding the relationship between division of matrimonial assets and maintenance.
Chan Tin Sun v Fong Quay SimCourt of AppealYes[2015] 2 SLR 195SingaporeCited regarding negative value of indirect non-financial contributions.
BUX v BUYN/AYes[2019] SGHCF 4SingaporeCited regarding the relationship between division of matrimonial assets and maintenance.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Women’s Charter (Cap 353, 2009 Rev Ed) s 112(1)Singapore
Women’s Charter (Cap 353, 2009 Rev Ed) s 112(10)Singapore
Women’s Charter (Cap 353, 2009 Rev Ed) s 113Singapore
Women’s Charter (Cap 353, 2009 Rev Ed) s 114(1)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Matrimonial Assets
  • Direct Contributions
  • Indirect Contributions
  • ANJ Approach
  • Adverse Inference
  • Lump Sum Maintenance
  • Dual-Income Marriage

15.2 Keywords

  • Divorce
  • Matrimonial Assets
  • Maintenance
  • Family Law
  • Singapore

17. Areas of Law

Area NameRelevance Score
Family Law95
Matrimonial Assets90
Maintenance85
Maintenance (Wife)80
Divorce75
Child Support10
Child Custody10

16. Subjects

  • Family Law
  • Divorce
  • Matrimonial Assets
  • Maintenance