WPN v WPO: Division of Matrimonial Assets and Wife's Maintenance in Divorce
In WPN v WPO, the Family Division of the High Court of Singapore, presided over by Justice Kwek Mean Luck, addressed the ancillary matters of a divorce between WPN (Wife) and WPO (Husband). The court ordered an equal division of the matrimonial assets, valued at S$31,259,918.62, and denied the Wife's request for spousal maintenance. The primary legal issues revolved around the valuation and division of assets, including shares in private companies, and the determination of an equitable distribution ratio considering the long-term, single-income nature of the marriage.
1. Case Overview
1.1 Court
Family Division of the High Court of the Republic of Singapore1.2 Outcome
Equal division of matrimonial assets ordered; spousal maintenance denied.
1.3 Case Type
Family
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Singapore High Court decision on division of matrimonial assets and spousal maintenance in a divorce case after a long marriage.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| WPN | Plaintiff | Individual | Equal division of matrimonial assets | Partial | Chew Wei En, Gill Carrie Kaur |
| WPO | Defendant | Individual | Equal division of matrimonial assets | Partial | Chong Siew Nyuk Josephine, Kym Calista Anstey |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Kwek Mean Luck | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Chew Wei En | Harry Elias Partnership LLP |
| Gill Carrie Kaur | Harry Elias Partnership LLP |
| Chong Siew Nyuk Josephine | Josephine Chong LLC |
| Kym Calista Anstey | Josephine Chong LLC |
4. Facts
- The Parties were married on 1 August 1988 and have two adult children.
- The Wife commenced divorce proceedings against the Husband on 29 December 2017.
- The Interim Judgment was granted on 28 January 2019.
- The Husband was the CEO of [C] Pte Ltd, a fintech startup.
- The Wife was a housewife for the majority of the marriage.
- The parties agreed that the Interim Judgment Date would serve as the cut-off date for ascertaining the pool of MAs.
- The Husband purchased a Porsche in July 2018 for S$225,000 after the commencement of divorce proceedings.
5. Formal Citations
- WPN v WPO, Divorce (Transferred) No 6040 of 2017, [2023] SGHCF 38
6. Timeline
| Date | Event |
|---|---|
| Parties married | |
| Wife commenced divorce proceedings | |
| Husband purchased a Porsche | |
| Interim judgment granted | |
| Husband sold shares in [B] to a Malaysian company | |
| Ancillary Matters hearing | |
| Judgment issued |
7. Legal Issues
- Division of Matrimonial Assets
- Outcome: The court ordered an equal division of the matrimonial assets.
- Category: Substantive
- Sub-Issues:
- Valuation of shares in private companies
- Inclusion of specific assets in the pool of matrimonial assets
- Appropriate ratio for division of assets in a long single-income marriage
- Spousal Maintenance
- Outcome: The court denied the Wife's request for spousal maintenance.
- Category: Substantive
8. Remedies Sought
- Division of Matrimonial Assets
- Spousal Maintenance
9. Cause of Actions
- Divorce
10. Practice Areas
- Divorce
- Family Law
- Asset Division
11. Industries
- Financial Technology
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| TNL v TNK | Court of Appeal | Yes | [2017] 1 SLR 609 | Singapore | Cited for the principle that a substantial sum expended by one spouse must be returned to the pool of matrimonial assets if the other spouse did not agree to the expenditure. |
| Lee Hsien Loong v Review Publishing Co Ltd and another and another suit | Court of Appeal | Yes | [2007] 2 SLR(R) 453 | Singapore | Cited for the court's power to choose between conflicting expert testimonies. |
| Armstong, 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 | Singapore | Yes | [2020] 1 SLR 133 | Singapore | Cited for the consideration of consistency, logic and coherence in deciding whether to reject or accept expert evidence. |
| CYH v CYI | High Court | Yes | [2023] SGHCF 4 | Singapore | Cited for the principle that a party should be responsible for the loss concretized by the lower price of shares obtained in a sale after the interim judgment date. |
| ANJ v ANK | Singapore | Yes | [2015] 4 SLR 1043 | Singapore | Cited to indicate that the structured approach in ANJ did not apply. |
| Yeo Chong Lin v Tay Ang Choo Nancy and another appeal | Court of Appeal | Yes | [2011] 2 SLR 1157 | Singapore | Cited as a case where the court deviated from equal division in a long single-income marriage due to the exceptionally large size of the asset pool. |
| UKA v UKB | Singapore | Yes | [2018] 4 SLR 779 | Singapore | Cited as a case involving a long marriage and a large pool of matrimonial assets where the court ordered equal division. |
| TOF v TOE | Singapore | Yes | [2021] 2 SLR 976 | Singapore | Cited as a case involving a long single-income marriage where the Court of Appeal indicated they would have awarded the wife an equal share of the matrimonial assets. |
| TNC v TND | Singapore | Yes | [2016] 3 SLR 1172 | Singapore | Cited for the classification methodology. |
| TND v TNC and another appeal | Court of Appeal | Yes | [2017] SGCA 34 | Singapore | Cited for upholding the decision in TNC to award the husband a higher proportion of matrimonial assets from one group of assets. |
| Oh Choon v Lee Siew Lin | Court of Appeal | Yes | [2014] 1 SLR 629 | Singapore | Cited for the principle that continued involvement and provision suggests the existence of a continuous relationship between the parties. |
| Chan Teck Hock David v Leong Mei Chuan | Singapore | Yes | [2002] 1 SLR(R) 76 | Singapore | Cited for the 'time rule'. |
| TQU v TQT | Court of Appeal | Yes | [2020] SGCA 8 | Singapore | Cited for the principle that courts have declined to award maintenance where a spouse has been awarded a substantial amount of the matrimonial assets. |
| UBM v UBN | Singapore | Yes | [2017] 4 SLR 921 | Singapore | Cited for the principle that courts have declined to award maintenance where a spouse has been awarded a substantial amount of the matrimonial assets. |
| VOW v VOV | Singapore | Yes | [2023] SGHCF 9 | Singapore | Cited for the principle that the valuation as agreed for use at the AM hearing should be adopted. |
| TIC v TID | Singapore | Yes | [2018] 1 SLR 180 | Singapore | Cited for the principle that mortgage payments and property tax paid by the Husband during the period before the transfer would accrue as his share of transfer to the Wife. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Women’s Charter 1961 | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Matrimonial Assets
- Interim Judgment Date
- Valuation Date
- Single-Income Marriage
- Fintech
- Shares
- CPF
- Spousal Maintenance
- Division of Assets
15.2 Keywords
- Divorce
- Matrimonial Assets
- Spousal Maintenance
- Singapore
- Family Law
- Asset Division
- Valuation
- Shares
- Fintech
16. Subjects
- Family Law
- Divorce
- Asset Division
- Spousal Support
17. Areas of Law
- Family Law
- Divorce Law
- Matrimonial Assets
- Division of Matrimonial Assets
- Spousal Maintenance