DBA v DBB: Division of Matrimonial Assets in Long Single-Income Marriage
In DBA v DBB, the Appellate Division of the High Court of Singapore heard an appeal regarding the division of matrimonial assets following a divorce. The court reclassified the marriage as a long single-income marriage, overturning the initial classification as dual-income. The court adjusted the asset division to 60:40 in favor of the husband, recognizing his significant financial contributions and the wife's role as primary homemaker. The court upheld the order for the husband to pay monthly maintenance for one child and denied maintenance for the wife.
1. Case Overview
1.1 Court
Appellate Division of the High Court of the Republic of Singapore1.2 Outcome
Appeal Allowed in Part
1.3 Case Type
Family
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal regarding the classification of marriage for asset division. The court reclassified it as a long single-income marriage, adjusting the asset division to 60:40 in favor of the husband.
1.7 Decision Date
2. Parties and Outcomes
3. Judges
Judge Name | Title | Delivered Judgment |
---|---|---|
Woo Bih Li | Judge of the Appellate Division | No |
Debbie Ong Siew Ling | Judge of the Appellate Division | Yes |
See Kee Oon | Judge of the Appellate Division | No |
4. Counsels
Counsel Name | Organization |
---|---|
Ang Hui Tsun | Louis Lim & Partners |
Augustine Thung Hsing Hua | Yeo & Associates LLC |
4. Facts
- The parties were married on 26 September 1990 and divorced after 31 years.
- The Wife was primarily the homemaker for the majority of the marriage.
- The Husband was primarily the breadwinner for the majority of the marriage.
- The Wife took on more flexible work to care for the children.
- The Husband left full-time employment in 2016 but continued contract work.
- The parties have three children, one of whom is a minor.
- The total pool of assets had a value of over $7 million.
5. Formal Citations
- DBA v DBB, Civil Appeal No 67 of 2023, [2024] SGHC(A) 12
6. Timeline
Date | Event |
---|---|
Parties married | |
Interim judgment of divorce granted | |
Husband to pay A$100,000 for [C’s] tertiary education | |
Husband to pay A$100,000 for [C’s] tertiary education | |
Hearing date | |
Grounds of decision delivered | |
Five Properties to be sold in the open market |
7. Legal Issues
- Classification of Marriage
- Outcome: The court reclassified the marriage as a long single-income marriage.
- Category: Substantive
- Sub-Issues:
- Dual-income marriage
- Single-income marriage
- Homemaker contributions
- Related Cases:
- [2015] 4 SLR 1043
- [2017] 1 SLR 609
- Division of Matrimonial Assets
- Outcome: The court ordered that the total pool of matrimonial assets be divided in the proportion of 60% to the Husband and 40% to the Wife.
- Category: Substantive
- Sub-Issues:
- Direct contributions
- Indirect contributions
- Valuation of assets
- CPF contributions
- Related Cases:
- [2015] 4 SLR 1043
- [2017] 1 SLR 609
- Child Maintenance
- Outcome: The court did not disturb the Judge’s order that the Husband pays $1,500 as monthly maintenance for [D].
- Category: Substantive
- Sub-Issues:
- Reasonable expenses
- Parents' duty to provide
- Wife Maintenance
- Outcome: The court did not disturb the Judge’s order that there would be no maintenance for her.
- Category: Substantive
- Sub-Issues:
- Financial preservation
- Standard of living
8. Remedies Sought
- Division of Matrimonial Assets
- Maintenance for Child
- Maintenance for Wife
- Transfer of Properties
9. Cause of Actions
- Divorce
- Division of Matrimonial Assets
- Maintenance
10. Practice Areas
- Divorce
- Family Law
- Appeals
11. Industries
- No industries specified
12. Cited Cases
Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
---|---|---|---|---|---|
ANJ v ANK | Court of Appeal | Yes | [2015] 4 SLR 1043 | Singapore | Cited for the structured approach in dividing matrimonial assets in dual-income marriages. |
TNL v TNK and another appeal and another matter | Court of Appeal | Yes | [2017] 1 SLR 609 | Singapore | Cited for the principle that the structured approach to division of matrimonial assets applies to dual-income marriages but not single-income marriages and for trends in precedent cases for long single-income marriages. |
BPC v BPB and another appeal | Court of Appeal | Yes | [2019] 1 SLR 608 | Singapore | Cited for the principle that one must first enquire whether the marriage is a long single-income or dual-income marriage. |
UBM v UBN | Family Division of the High Court | Yes | [2017] 4 SLR 921 | Singapore | Cited for the definition of a single-income marriage and the principle that the homemaker may work part-time or intermittently over the course of the marriage. |
Yow Mee Lan v Chen Kai Buan | Unknown | Yes | [2000] 2 SLR(R) 659 | Singapore | Cited as an instance of a long single-income marriage where the wife worked continuously during the marriage. |
USB v USA and another appeal | Court of Appeal | Yes | [2020] 2 SLR 588 | Singapore | Cited for the principle that the starting point of the division exercise is the identification of the material gains of the marital partnership. |
CVC v CVB | High Court | Yes | [2023] SGHC(A) 28 | Singapore | Cited for the principle that the total pool of matrimonial assets ought to have been identified and valued before the first step of the ANJ approach is taken and for the legal principles regarding repayment of CPF contributions. |
Yeo Chong Lin v Tay Ang Choo Nancy and another appeal | Court of Appeal | Yes | [2011] 2 SLR 1157 | Singapore | Cited to show that there is no immutable rule requiring that each party in a long single-income marriage should receive a 50% share. |
WBU v WBT | Singapore High Court | Yes | [2023] SGHCF 3 | Singapore | Cited for the principle that a broad-brush approach is appropriate in both the quantification of child maintenance and the apportionment of the maintenance obligation as between the parties. |
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
- Dual-income marriage
- Single-income marriage
- Homemaker
- Breadwinner
- Direct contributions
- Indirect contributions
- Child maintenance
- Wife maintenance
- CPF contributions
15.2 Keywords
- divorce
- matrimonial assets
- single-income marriage
- child maintenance
- wife maintenance
- family law
17. Areas of Law
Area Name | Relevance Score |
---|---|
Family Law | 95 |
Division of Matrimonial Assets | 90 |
Matrimonial Home | 85 |
Maintenance (Child) | 80 |
Maintenance | 75 |
Maintenance (Wife) | 70 |
Care and Control | 60 |
Access to Children | 50 |
Wills and Probate | 10 |
Trust Law | 5 |
16. Subjects
- Family Law
- Divorce
- Matrimonial Assets
- Maintenance