WXW v WXX: Division of Matrimonial Assets in a Dual-Income Marriage

In WXW v WXX, the Appellate Division of the High Court of Singapore heard an appeal regarding the division of matrimonial assets following a divorce. The key issue was whether the marriage was a single-income or dual-income marriage. The court determined that it was a dual-income marriage and applied the ANJ approach, dividing the matrimonial assets in a 67:33 ratio in favor of the Wife. The court set aside the original division order.

1. Case Overview

1.1 Court

Appellate Division of the High Court of the Republic of Singapore

1.2 Outcome

Appeal Allowed in Part

1.3 Case Type

Family

1.4 Judgment Type

Ex Tempore Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Appeal regarding division of matrimonial assets. The court determined the marriage was dual-income, applying the ANJ approach and adjusting the division ratio.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
WXWAppellantIndividualAppeal Allowed in PartPartial
WXXRespondentIndividualAppeal Partially UnsuccessfulPartial

3. Judges

Judge NameTitleDelivered Judgment
Woo Bih LiJudge of the Appellate DivisionNo
Debbie Ong Siew LingJudge of the Appellate DivisionYes
Mavis Chionh Sze ChyiJudge of the High CourtNo

4. Counsels

Counsel NameOrganization
Aye Cheng ShoneA C Shone & Co
Natasha Choo Sen YewA C Shone & Co
Wong Shoou-Huang JonathanTembusu Law LLC

4. Facts

  1. The Wife and Husband were married in January 1988 and divorced in 2022.
  2. The Wife worked full-time throughout the marriage.
  3. The Husband worked full-time for nine years and then intermittently.
  4. The Judge valued the total pool of matrimonial assets at S$7,795,484.21.
  5. The parties had at least one helper throughout the marriage.
  6. The parties have three adult children.
  7. The Wife was the sole breadwinner for the majority of the marriage.

5. Formal Citations

  1. WXW v WXX, Civil Appeal No 65 of 2024, [2025] SGHC(A) 2
  2. WXW v WXX, , [2025] SGHC(A) 2
  3. WXW v WXX, , [2024] SGHCF 24

6. Timeline

DateEvent
Parties married
Husband left full-time employment at bank
Husband operated fried noodles hawker stall for two months
Husband incarcerated for six months
Husband offered services for a wedding planning company for four years
Husband conducted ad hoc Financial Futures and Options Markets classes for four years
Husband acted as a guest speaker in Malaysia on financial markets for six years
Husband acted as the managing director of a private company for one year
Husband paid a one-time bonus of S$5,000
Interim judgment of divorce granted
Judge's grounds of decision issued
Judgment delivered

7. Legal Issues

  1. Classification of Marriage as Single-Income or Dual-Income
    • Outcome: The court held that the marriage was a dual-income marriage.
    • Category: Substantive
    • Related Cases:
      • [2017] 1 SLR 609
      • [2015] 4 SLR 1043
  2. Division of Matrimonial Assets
    • Outcome: The court ordered that the matrimonial assets be divided in the ratio of 67:33 in favor of the Wife.
    • Category: Substantive
    • Related Cases:
      • [2017] 1 SLR 609
      • [2015] 4 SLR 1043

8. Remedies Sought

  1. Division of Matrimonial Assets

9. Cause of Actions

  • No cause of actions

10. Practice Areas

  • Divorce
  • Family Law
  • Matrimonial Asset Division

11. Industries

  • No industries specified

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
TNL v TNK and another appeal and another matterCourt of AppealYes[2017] 1 SLR 609SingaporeCited for the principles applicable to the division of matrimonial assets in single-income marriages.
ANJ v ANKUnknownYes[2015] 4 SLR 1043SingaporeCited for the structured approach to dividing matrimonial assets in dual-income marriages.
UYP v UYQUnknownYes[2020] 3 SLR 683SingaporeEndorsed on appeal in UYQ v UYP [2020] 1 SLR 551 at [1]. It is also referred to as the “structured approach”, containing a few structured “steps”.
UYQ v UYPUnknownYes[2020] 1 SLR 551SingaporeEndorsed UYP v UYQ [2020] 3 SLR 683 at [58].
DBA v DBBAppellate Division of the High CourtYes[2024] 1 SLR 459SingaporeCited to clarify that a large disparity in income between spouses does not automatically render a marriage a single-income marriage.
UBM v UBNUnknownYes[2017] 4 SLR 921SingaporeCited for the principle that the key enquiry focuses on the roles undertaken and discharged by the spouses during the marriage.
NK v NLCourt of AppealYes[2007] 3 SLR(R) 743SingaporeCited for the principle that the division of matrimonial assets is founded on the ideology of marriage as an equal co-operative partnership of efforts.
USB v USA and another appealCourt of AppealYes[2020] 2 SLR 588SingaporeCited for the principle that the broad-brush approach should be applied with particular vigour in assessing the parties’ indirect contributions.
Yeo Chong Lin v Tay Ang Choo NancyUnknownYes[2011] 2 SLR 1157SingaporeCited as an example of a long single-income marriage where the assets were not divided equally due to the exceptionally large size of the asset pool.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Women’s Charter 1961 (2020 Rev Ed)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Matrimonial Assets
  • Single-Income Marriage
  • Dual-Income Marriage
  • ANJ Approach
  • TNL Approach
  • Division Ratio
  • Homemaker
  • Breadwinner

15.2 Keywords

  • matrimonial assets
  • division
  • divorce
  • family law
  • dual-income marriage
  • single-income marriage

17. Areas of Law

Area NameRelevance Score
Family Law95
Division of Matrimonial Assets95
Divorce60
Child Custody20

16. Subjects

  • Family Law
  • Divorce
  • Matrimonial Assets