Rohan St George v 4Fingers Pte Ltd: Production of Documents Dispute
In Rohan St George v 4Fingers Pte Ltd and LS Investments Holdings Pte Ltd, the Singapore High Court addressed applications related to the production of documents in a civil claim. Rohan St George is claiming payments due from his employment with 4Fingers Pte Ltd, while the defendants are pursuing counterclaims for breaches of fiduciary and/or contractual duties. The court allowed both the claimant's and the defendants' applications for document production in part, providing detailed reasons for the decision.
1. Case Overview
1.1 Court
General Division of the High Court1.2 Outcome
Both applications allowed in part.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Singapore High Court addresses applications for document production in a dispute over employment terms and alleged breaches of contract.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Rohan St George | Claimant | Individual | Application Allowed in Part | Partial | |
| 4Fingers Pte Ltd | Defendant | Corporation | Application Allowed in Part | Partial | |
| LS Investments Holdings Pte Ltd | Defendant | Corporation | Application Allowed in Part | Partial |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Perry Peh | Assistant Registrar | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Joshua Quek | Drew & Napier LLC |
| Li Jiabao | LVM Law Chambers LLC |
| Thong Ying Xuan | LVM Law Chambers LLC |
4. Facts
- Rohan St George claimed payments due from his employment with 4Fingers Pte Ltd.
- The defendants pursued counterclaims for breaches of fiduciary and/or contractual duties.
- The claims were based on an employment contract and subsequent addenda.
- A key dispute was whether the termination of employment was unlawful.
- The parties disputed the effect of addenda on the original employment contract.
- The parties disputed whether certain agreements were reached during meetings.
5. Formal Citations
- Rohan St George v 4Fingers Pte Ltd and another, Originating Claim No 740 of 2023 (Summonses Nos 1276 and 1277 of 2024), [2024] SGHCR 9
6. Timeline
| Date | Event |
|---|---|
| Employment contract entered into between Rohan St George and 4Fingers Pte Ltd. | |
| First addendum entered into. | |
| Second addendum entered into. | |
| Third addendum entered into. | |
| Agreement entered into between Rohan St George and LS Investments Holdings Pte Ltd. | |
| Meeting between Rohan St George and June Lee. | |
| Board meeting of 4Fingers Pte Ltd. | |
| Meeting between Rohan St George and June Lee. | |
| Meeting between Rohan St George and June Lee. | |
| Meeting between Rohan St George and June Lee. | |
| 4Fingers Pte Ltd terminated Rohan St George’s employment. | |
| Claimant's and Defendants' list of documents. | |
| Hearing Date | |
| Hearing Date | |
| Judgment Date |
7. Legal Issues
- Production of Documents
- Outcome: The court partially allowed both applications for production, determining the scope and conditions for document production.
- Category: Procedural
- Sub-Issues:
- Materiality of documents
- Possession or control of documents
- Sufficiency of identification of documents
- Breach of Contract
- Outcome: The court's decisions on document production were made in the context of assessing the breach of contract claims.
- Category: Substantive
- Sub-Issues:
- Termination of employment
- Validity of addenda
- Interpretation of contract terms
- Parol Evidence Rule
- Outcome: The court held that the parol evidence rule is not relevant in the court’s assessment of whether requested documents satisfy the requirement of materiality.
- Category: Substantive
8. Remedies Sought
- Production of Documents
- Monetary Compensation
9. Cause of Actions
- Breach of Contract
- Breach of Fiduciary Duty
10. Practice Areas
- Commercial Litigation
- Discovery
11. Industries
- Food and Beverage
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Eng’s Wantan Noodle Pte Ltd and another v Eng’s Char Siew Wantan Mee Pte Ltd | High Court | Yes | [2023] SGHCR 17 | Singapore | Cited for the principles regarding the conditions for ordering the production of requested documents. |
| Cachet Multi Strategy Fund SPC on behalf of Cachet Special Opportunities SP v Feng Shi and others | High Court | Yes | [2024] SGHCR 8 | Singapore | Cited for the principles regarding the conditions for ordering the production of requested documents. |
| Lutfi Salim bin Talib and another v British and Malayan Trustees Ltd | High Court | Yes | [2024] SGHC 85 | Singapore | Cited for the principles regarding the standard to be applied when a respondent objects to an application for specific production. |
| Zurich Insurance (Singapore) Pte Ltd v B-Gold Interior Design & Construction Pte Ltd | Court of Appeal | Yes | [2008] 3 SLR(R) 1029 | Singapore | Cited for the principles regarding the parol evidence rule. |
| Sembcorp Marine Ltd v PPL Holdings Pte Ltd and another and another appeal | Court of Appeal | Yes | [2013] 4 SLR 193 | Singapore | Cited for the principles regarding the admissibility of evidence. |
| Dante Yap Go v Bank Austria Creditanstalt AG | High Court | Yes | [2007] SGHC 69 | Singapore | Cited for the purpose of document production in civil procedure. |
| DFD v DFE and another | High Court | Yes | [2024] SGHCR 4 | Singapore | Cited for the purpose of document production in civil procedure. |
| CZD v CZE | High Court | Yes | [2023] 5 SLR 806 | Singapore | Cited for the interpretation of the term 'special case' in the context of document production. |
| Interactive Digital Finance Ltd and another v Credit Suisse AG and another | High Court | Yes | [2023] SGHC 198 | Singapore | Cited for the principle that reference to documents in pleadings is a form of disclosure. |
| Banque Cantonale de Geneve SA v Allen & Gledhill LLP | High Court | Yes | [2010] SGHC 39 | Singapore | Cited for the definition of 'fishing' in the context of document production. |
| DMX Technologies Group Ltd (in liquidation) v Deloitte & Touche LLP | High Court | Yes | [2022] SGHCR 2 | Singapore | Cited for the grounds on which a party can resist the making of an order for production of documents. |
| Rafidain Bank v Agom Universal Sugar Trading Co Ltd and another | English Court of Appeal | Yes | [1987] 1 WLR 1606 | England and Wales | Cited for the court's discretion in making an order to compel production for inspection. |
| Frogmore Estates Plc v Berger & others | Unknown | Yes | [1992] Lexis Citation 3650 | England and Wales | Cited for the grounds on which a party can rely to resist the making of an order for production. |
| Fermin Aldabe v Standard Chartered Bank | High Court | Yes | [2009] SGHC 194 | Singapore | Cited for a party’s right of inspection arises in respect of the originals of the documents in question |
| Comfort Management Pte Ltd v OGSP Engineering Pte Ltd and another | High Court | Yes | [2022] SGHC 77 | Singapore | Cited for the starting point is that costs are ordered in favour of a successful party |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Rules of Court 2021 | Singapore |
| Evidence Act 1893 | Singapore |
| Companies Act 1967 (2020 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Production of documents
- Employment contract
- Addenda
- Termination
- Breach of contract
- Parol evidence rule
- Materiality
- Possession
- Control
- Native format
- Inspection
15.2 Keywords
- document production
- civil procedure
- contract dispute
- employment law
- Singapore High Court
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Discovery of documents | 90 |
| Civil Practice | 75 |
| Contractual terms | 40 |
| Fiduciary Duties | 30 |
16. Subjects
- Civil Procedure
- Contract Law
- Employment Law
- Discovery