Ten-League Corporations Pte Ltd v Debenho Pte Ltd: Sale of Goods - Satisfactory Quality & Proof of Evidence

In Ten-League Corporations Pte Ltd v Debenho Pte Ltd, the Singapore High Court heard an appeal regarding a District Court's decision that a boom lift sold by Ten-League Corporations Pte Ltd (the seller) to Debenho Pte Ltd (the buyer) was not of satisfactory quality. The buyer claimed the boom lift was unsafe after a tilting incident. Philip Jeyaretnam J allowed the seller's appeal, finding that the buyer failed to prove the boom lift was unsafe and that the tilting incident was likely due to improper operation, not a defect in the equipment.

1. Case Overview

1.1 Court

General Division of the 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

Singapore High Court case regarding a boom lift's satisfactory quality under the Sale of Goods Act. The court allowed the appeal, finding the buyer failed to prove the boom lift was unsafe.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Ten-League Corporations Pte LtdAppellantCorporationAppeal AllowedWon
Debenho Pte LtdRespondentCorporationClaim DismissedLost

3. Judges

Judge NameTitleDelivered Judgment
Philip JeyaretnamJudge of the High CourtYes

4. Counsels

Counsel NameOrganization
Koh Kok KwangCTLC Law Corporation
Kenii TakashimaCTLC Law Corporation
Lim Kim HongKim & Co
Lim Teng JieKim & Co

4. Facts

  1. The seller supplied a boom lift to the buyer.
  2. The boom lift had two booms: an upper and a lower one.
  3. The boom lift had a tilt sensor that would trigger an automatic shut off if the chassis reached 3 degrees of inclination.
  4. The boom lift received a certificate of test before delivery.
  5. During operation, one of the wheels of the boom lift lifted off the ground, triggering shut off.
  6. The buyer complained that the boom lift was unsafe for use.
  7. The seller installed angle sensors and modified the computer program to limit the upper boom's operation without the lower boom.

5. Formal Citations

  1. Ten-League Corporations Pte Ltd v Debenho Pte Ltd, District Court Appeal No 25 of 2021, [2022] SGHC 32
  2. Debenho Pte Ltd v Ten League Corporations Pte Ltd, , [2021] SGDC 199

6. Timeline

DateEvent
Certificate of test issued for the Boom Lift
Boom Lift delivered and fully paid for
Tilting incident occurred during operation
Buyer complained the Boom Lift was unsafe
Seller cautioned buyer not to operate the Boom Lift
Service engineer inspected the Boom Lift
Angle sensors installed and computer program modified
Buyer raised concern about platform rocking
Buyer issued solicitors’ demand letter seeking a refund
Buyer commenced proceedings
Trial began
Trial concluded
District Judge found for the buyer
Hearing on appeal
Hearing on appeal
Judgment reserved

7. Legal Issues

  1. Satisfactory Quality
    • Outcome: The court found that the buyer failed to prove the boom lift was not of satisfactory quality.
    • Category: Substantive
    • Sub-Issues:
      • Fitness for purpose
      • Safety
  2. Burden of Proof
    • Outcome: The court clarified that the legal burden of proof was on the buyer to establish that the boom lift was of unsatisfactory quality, and it was an error to effectively reverse that burden by requiring the seller to prove improper usage on a balance of probabilities.
    • Category: Procedural
    • Sub-Issues:
      • Evidential burden
      • Tactical burden

8. Remedies Sought

  1. Full Refund of Purchase Price

9. Cause of Actions

  • Breach of Implied Condition of Satisfactory Quality

10. Practice Areas

  • Commercial Litigation

11. Industries

  • Construction

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Ma Hongjin v SCP Holdings Pte LtdCourt of AppealYes[2021] 1 SLR 304SingaporeCited for the description of the shifting of the evidential burden between the parties.
Debenho Pte Ltd v Ten League Corporations Pte LtdDistrict CourtYes[2021] SGDC 199SingaporeThe district court decision that was appealed in this case.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Sale of Goods Act 1979Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Boom Lift
  • Tilt Sensor
  • Upper Boom
  • Lower Boom
  • Tilting Incident
  • Angle Sensors
  • Satisfactory Quality
  • Improper Usage

15.2 Keywords

  • boom lift
  • sale of goods
  • satisfactory quality
  • tilting incident
  • construction equipment
  • Singapore
  • commercial dispute

17. Areas of Law

Area NameRelevance Score
Sale of Goods80
Contract Law75
Satisfactory Quality75
Commercial Law70
Breach of Contract60
Performance of Contract50
Evidence40

16. Subjects

  • Sale of Goods
  • Commercial Law
  • Equipment Safety