VRJ v VRK: Appeal for Interim Maintenance Dismissed in Divorce Proceedings
In VRJ v VRK, the High Court (Family Division) heard the appellant wife's appeal against the District Judge's decision to dismiss her application for interim maintenance from the respondent husband. The parties were undergoing contested divorce proceedings based on the husband's alleged adultery and unreasonable behavior. The court dismissed the wife's appeal, finding that she had sufficient funds to meet her and the children's immediate financial needs, and that the husband's existing contributions were reasonable under the circumstances.
1. Case Overview
1.1 Court
General Division of the High Court (Family Division)1.2 Outcome
Appeal dismissed.
1.3 Case Type
Family
1.4 Judgment Type
Judgment
1.5 Jurisdiction
Singapore
1.6 Description
Appeal for interim maintenance dismissed. The wife's access to substantial funds deemed sufficient to meet immediate financial needs during divorce proceedings.
1.7 Decision Date
2. Parties and Outcomes
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Choo Han Teck | Judge of the High Court | Yes |
4. Counsels
4. Facts
- The parties were married on 15 September 2007 and have two children.
- The wife quit her job in June 2019 to pursue postgraduate education.
- The wife withdrew $558,741.33 from the parties’ joint CIMB FastSaver Account.
- The wife filed for divorce on 22 January 2020 based on the husband’s adultery and unreasonable behaviour.
- The wife withdrew $130,510.00 from the parties’ joint DBS Savings Account.
- The wife has access to funds of at least $689,251.33.
- The husband is paying for the domestic helper’s expenses and part of the children’s insurance.
5. Formal Citations
- VRJ v VRK, Registrar’s Appeal from the Family Justice Courts No 6 of 2021, [2021] SGHCF 9
6. Timeline
| Date | Event |
|---|---|
| Parties married | |
| Son born | |
| Daughter born | |
| Wife quit her job | |
| Wife decided to end the marriage | |
| Wife moved out | |
| Wife filed for contested divorce | |
| Wife amended writ for divorce to include co-defendant | |
| Wife applied for interim maintenance | |
| Wife’s application was dismissed | |
| Judgment reserved | |
| Judgment issued | |
| Divorce trial fixed for 2 days |
7. Legal Issues
- Interim Maintenance
- Outcome: The court held that the wife was not entitled to interim maintenance because she had access to substantial funds and the husband was making reasonable contributions.
- Category: Substantive
- Sub-Issues:
- Reasonable maintenance
- Financial needs
- Access to funds
8. Remedies Sought
- Interim Maintenance
9. Cause of Actions
- Adultery
- Unreasonable behaviour
10. Practice Areas
- Divorce
- Family Law
- Appeals
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| TCT v TCU | High Court | Yes | [2015] 4 SLR 227 | Singapore | Cited for the principle that a court will not interfere before a case is heard unless there is a clear need for it, and that an interim maintenance order would not normally be made unless there is a clear need for it. |
| Foo Ah Yan v Chiam Heng Chow | Unknown | Yes | [2012] 2 SLR 506 | Singapore | Cited for the principle that the objective of an interim maintenance order is to provide modest maintenance to help the parties meet their immediate financial needs. |
| Lee Bee Kim Jennifer v Lim Yew Khang Cecil | High Court | Yes | [2005] SGHC 209 | Singapore | Cited for the principle that at the interim stage, the court does not have the full means to make a thorough investigation of the parties’ financial matters or their lifestyles, and thus the court will usually err on the side of conservatism. |
| AMW v AMZ | Unknown | Yes | [2011] 3 SLR 955 | Singapore | Cited for the principle that the court can make final orders on the issue of maintenance, which would include backdating any maintenance if the court thinks that to be fair, even to a date before the writ was filed. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Women’s Charter (Cap 353, 2009 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Interim maintenance
- Matrimonial assets
- Contested divorce
- Ancillary matters
- Reasonable maintenance
15.2 Keywords
- divorce
- family law
- interim maintenance
- appeal
- Singapore
17. Areas of Law
16. Subjects
- Family Law
- Divorce
- Maintenance