As enacted

Commentary · As enacted

[SAL Ann Rev]: Family law

The text

(2024)

25 SAL Ann Rev 1

(Published on e-First 28 September 2026)

17. FAMILY LAW

Tricia HO1

LLB (Singapore Management University),

LLM (University of California, Berkeley),

JSD candidate (University of California, Berkeley);

Advocate and Solicitor (Singapore);

Lecturer, School of Law, Singapore University of Social Sciences;

Consultant, Dentons Rodyk & Davidson LLP.

Aaron YOONG

LLB (Summa Cum Laude) (Singapore Management University),

LLM (Harvard);

Advocate and Solicitor (Singapore);

Assistant Professor, Yong Pung How School of Law, Singapore

Management University.

17.1

The review of 2025 focuses on trends with respect to maintenance, an area of the law that has been gradually transformed with the practical application of therapeutic justice (“TJ”). The

Appellate Division of the High Court (“Appellate Division”) laid down key principles that emphasise the distinction between maintenance in a subsisting marriage and interim maintenance on the one hand, and final maintenance orders made in the context of an ancillary matters hearing on the other. Further, the Family Division of the High Court (“HCF”)

provided guidance on the application of the “budget” approach2 and nominal maintenance. This year’s review also highlights three key developments in the division of matrimonial assets. On identifying matrimonial assets, the HCF provided clarification on when premarital assets may be transformed by way of “substantial improvement”.3 On dividing matrimonial assets, the Appellate Division provided further guidance on distinguishing between single and dual-income marriages.

Finally, the HCF set out a clear standard for when giving effect to adverse inferences justified applying both the quantification and uplift approaches. This review also covers key cases involving child issues and procedure.

The authors are grateful to Ezra Lim for the significant input he provided for this article. All errors remain the authors’ own.

WZF v WZG [2025] 3 SLR 1219 at [104].

XIB v XIA [2025] SGHCF 40 at [27].

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Maintenance 17.2

In 2025, the Appellate Division delivered a noteworthy decision on the interaction between the various maintenance provisions in the

Women’s Charter 19614 (“WC”). In XHG v XHH5 (“XHG”), the Appellate

Division provided clarity on: (a) child and former spousal maintenance in the final ancillary matters context; and (b) when the legal requirement for “neglect or refusal”6 to provide reasonable maintenance would apply.

17.3

The husband in XHG filed an appeal against the HCF’s final ancillary matters order in respect of:7

(a)

the amount of $2,386 per month being a reasonable sum for the children’s enrichment class expenses;

(b)

the backdating of child maintenance amounting to $17,000;

(c)

the backdating of spousal maintenance for the wife amounting to $144,000;

(d)

the 50:50 ratio for the parties’ indirect contributions to the marriage;

(e)

the 3.5% uplift to the final division ratio to account for the wife’s rent-free occupation of the matrimonial home from

May 2022; and

(f)

standard and indemnity costs awarded to the wife.

17.4

First, the Appellate Division upheld the sum of $2,386 per month as a reasonable sum for the children’s enrichment class expenses.8 The

HCF derived that amount from the sums the husband claimed he was paying each month for the children’s enrichment classes and what the husband deemed reasonable for any additional enrichment classes. There was no double counting of moneys that the husband paid directly to the providers, as the HCF had estimated a reasonable sum for the children’s enrichment classes generally and the parties were to sort out between themselves which classes they would like the children to attend. The

Appellate Division recognised that such a “budget” approach was indeed a sensible way to address the children’s changing needs with age and 4 2020 Rev Ed.

[2025] 2 SLR 501.

XHG v XHH [2025] 2 SLR 501 at [36].

XHG v XHH [2025] 2 SLR 501 at [18].

XHG v XHH [2025] 2 SLR 501 at [22]–[26].

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Family Law encouraged the sensible discharge of shared parental responsibility in that respect.9 17.5

Second, as part of the ancillary matters orders, the HCF ordered the husband to pay $17,000 of backdated lump sum children’s maintenance based on the difference between the eventual amount he was ordered to contribute towards the children’s reasonable maintenance and the amount he had in fact paid from August 2023 to March 2024.10 The husband argued that the backdating of child maintenance implicated the doctrine of issue estoppel, given that the HCF had previously dismissed the Family Court’s orders for him to pay interim child maintenance in

July 2023.11 The Appellate Division upheld the HCF’s backdated child maintenance order.12 It held that a successful invocation of issue estoppel required a final and conclusive judgment on the merits, a court of competent jurisdiction, an identity of parties between the two actions and an identity of subject matter in the two actions. Of relevance here was the “identity of subject matter” factor, whereby the litigated issue in both actions had to be identified and proven by the husband to be identical.13

The Appellate Division held that there was no “identity of subject matter”

between the issues decided in the wife’s earlier application for interim child maintenance (that resulted in the Family Court’s interim child maintenance orders that were dismissed by the HCF in July 2023) and the more recent ancillary matters order on backdated child maintenance.14

The periods in question were distinct,15 resulting in there being no

“identity of subject matter”.

17.6

Section 69(2) of the WC governs when the court may order interim child maintenance. It must be shown that “a parent has neglected or refused to provide reasonable maintenance for his or her child”.16 At the conclusion of the wife’s interim maintenance application and on appeal, both the Family Court and HCF found that the evidence did not support a finding of such neglect or refusal for the period sought by the wife.17 The consideration of “neglect or refusal” at the time the application for interim child maintenance was made in September 2022 was distinct from the HCF’s decision to award backdated child maintenance for the period of August to December 2023. Significantly, this period was after 9

XHG v XHH [2025] 2 SLR 501 at [24].

XHG v XHH [2025] 2 SLR 501 at [14]–[15].

XHG v XHH [2025] 2 SLR 501 at [8]–[9].

XHG v XHH [2025] 2 SLR 501 at [33].

XHG v XHH [2025] 2 SLR 501 at [34]–[35].

XHG v XHH [2025] 2 SLR 501 at [35].

Women’s Charter 1961 (2020 Rev Ed) s 69(2).

XHG v XHH [2025] 2 SLR 501 at [36].

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25 SAL Ann Rev the HCF had set aside the Family Court’s interim child maintenance orders in July 2023. Any finding from that earlier period was not determinative of whether the husband neglected or refused to maintain the children for the subsequent period of August to December 2023. As such, the Appellate Division held that the factual issues were not identical and issue estoppel did not arise.18 17.7

In response to the husband’s additional arguments against the award of backdated child maintenance, the Appellate Division held that

AXM v AXO19 (“AXM”) was not relevant as there were no overlapping orders in the present case. The Court of Appeal in AXM was concerned with an overlap of periods between an existing interim maintenance order and a backdated final maintenance order made at the ancillary matters stage covering the same period. This concern did not arise on the facts of XHG as there was no existing interim maintenance order to overlap with.20 The Appellate Division was similarly unpersuaded by the husband’s argument that the wife had sufficient resources to meet the children’s needs during that period because both parents had the duty to maintain their children.21 The Appellate Division held that the wife need only show that the husband was not contributing his fair share towards the children’s maintenance, considering their respective incomes and other financial resources.22 17.8

The HCF had made a factual finding that the husband maintained the children at an average of $3,722 per month from August 2023 to March 2024. Given the eventual ancillary matters order for the husband to contribute reasonable child maintenance of $4,819 per month, he had under-contributed by an approximate amount of $1,000

per month from the period of August 2023 to March 2024. Accordingly, the HCF ordered backdated child maintenance of $1,000 per month to be paid for that period, amounting to the lump sum of $17,000. That lump sum payment was upheld by the Appellate Division in XHG.23 17.9

While the parties did not raise the issue specifically, the Appellate

Division noted that the husband’s argument of issue estoppel brought into focus the question of whether the requirement of “neglect or refusal”

in s 69(2) of the WC governing interim child maintenance also applied to final child maintenance at the ancillary matters stage.24 The answer 18

XHG v XHH [2025] 2 SLR 501 at [37].

[2014] 2 SLR 705.

XHG v XHH [2025] 2 SLR 501 at [39].

XHG v XHH [2025] 2 SLR 501 at [41].

XHG v XHH [2025] 2 SLR 501 at [43].

XHG v XHH [2025] 2 SLR 501 at [42] and [44].

XHG v XHH [2025] 2 SLR 501 at [45].

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Family Law would depend on the proper construction of the interplay between ss 69(2) and 127(2) of the WC.25 In providing its provisional views, the Appellate Division observed that final ancillary matters orders for child maintenance had been routinely made without a determination of whether the paying parent had neglected or refused to maintain the child within the meaning of s 69(2).26 This is despite s 127(2) providing that

“[p]arts 8 and 9 apply, with the necessary modifications, to an application for maintenance” when the court granted a divorce or subsequent to the grant of divorce.

17.10

Applying a purposive approach to the interpretation of s 127(2)

of the WC would require ascertaining whether one of the “necessary modifications” contemplated may exclude the requirement of neglect or refusal in s 69(2) when child maintenance is sought as a final ancillary matters order in divorce proceedings.27 The Appellate Division was of the provisional view that based on the legislative history of s 127(2),

Parliament did not intend to impose the requirement of proof of neglect or refusal where child maintenance was sought as a final ancillary matters order.28 This distinction was evident in the older version of the Women’s

Charter29 (ie, the 1985 Revised Edition) that provided two separate provisions for ordering child maintenance: (a) s 61(2) that required proof of neglect or refusal of the parent to maintain outside of matrimonial proceedings; and (b) ss 122(1) and 122(2) that did not contain such a requirement where there were matrimonial proceedings.30 17.11

In 1996, the Women’s Charter (Amendment) Act 199631 repealed and re‑enacted the abovementioned sections with wordings that were largely similar to or the same as the provisions in the current version of the

WC.32 As part of representations submitted to the Select Committee on the Women’s Charter (Amendment) Bill, Prof Leong Wai Kum suggested that rationalisation of the law required that the provision which laid down the extent of the parents’ duty to maintain their child (which was exactly the same during marriage or upon divorce) should only appear once under s 61(2) of the WC. The operational mechanics for invoking that duty may then be separately provided for in Pt VII of the Women’s 25

XHG v XHH [2025] 2 SLR 501 at [38].

XHG v XHH [2025] 2 SLR 501 at [46].

XHG v XHH [2025] 2 SLR 501 at [48].

XHG v XHH [2025] 2 SLR 501 at [49].

Cap 353, 1985 Rev Ed.

XHG v XHH [2025] 2 SLR 501 at [50].

Act 30 of 1996.

XHG v XHH [2025] 2 SLR 501 at [51]–[52].

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Charter33 for existing marriages and Pt XI of the Women’s Charter34 for parents in the process of terminating their marriage.35 Subsequently, there were no relevant mentions of the amendments at the Second or

Third Readings of the Bill.36 17.12

The Appellate Division inferred from the legislative background that the amendments were not intended to effect a substantial change to the law on child maintenance, and were instead targeted at a specific issue of there being two apparently distinct notions of a parent’s substantive duty to maintain his or her child.37 In light of this, the Appellate Division reasoned that s 127 of the WC was unlikely meant to impose a more rigorous standard of proof than the position under s 122 of the earlier version of the Women’s Charter.38 In essence, legislative history suggested that there was no requirement for proof of a parent’s neglect or refusal to maintain in child maintenance proceedings instituted upon divorce.39 17.13

In further support of its conclusion, the Appellate Division noted that the reasons underlying child maintenance orders in a subsisting marriage under s 69(2) of the WC differed from those for ancillary matters child maintenance orders under s 127(1). In a subsisting marriage, the court will only intervene in the private family domain if there is a clear failure of a legal duty, ie, proof of neglect or refusal by a parent to maintain the child.40 In contrast, the court’s task in the ancillary matters context is to ensure that family obligations continue to be discharged after the drastic event of a divorce. This is independent of whether a parent had neglected or refused to maintain the child in the past. Child maintenance orders are meant to protect the children’s best interests in a forward‑looking manner following the dissolution of their parents’ marriage and reorganisation of the family’s living and financial arrangements.41 In conclusion, the Appellate Division held that the interpretation of s 127(2) of the WC that best furthered the legislative purpose and the nature of the judicial task in ancillary matters proceedings would be to read “necessary modifications” as excluding the neglect or refusal requirement.42 33

Act 30 of 1996.

XHG v XHH [2025] 2 SLR 501 at [53]–[54].

XHG v XHH [2025] 2 SLR 501 at [55].

XHG v XHH [2025] 2 SLR 501 at [49] and [56].

Cap 353, 1985 Rev Ed.

XHG v XHH [2025] 2 SLR 501 at [56].

XHG v XHH [2025] 2 SLR 501 at [57].

XHG v XHH [2025] 2 SLR 501 at [58].

XHG v XHH [2025] 2 SLR 501 at [59].

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Family Law 17.14

Third, the Appellate Division set aside the HCF’s decision to award the wife backdated maintenance of $144,000. It again dismissed the husband’s arguments on AXM and issue estoppel on the respective bases that there was no subsisting interim maintenance order for the wife that could overlap with a backdated spousal maintenance order granted at the ancillary matters stage43 and no identity of subject matter. The lack of identity of subject matter was bolstered by the distinct purposes of interim maintenance during the course of matrimonial proceedings

(under s 113(1)(a) of the WC) and former spousal maintenance when granting or subsequent to the grant of a judgment of divorce (under s 113(1)(b) of the WC). Interim maintenance in a subsisting marriage

(and during pending divorce proceedings) is to provide for the wife’s immediate financial needs subject to proof of neglect or refusal to maintain, whereas former spousal maintenance is meant to enable the former wife to continue to live at the level that she did immediately prior to the breakdown of the marriage, so far as it is practical. In other words, former spousal maintenance is for the wife to achieve “financial preservation”.44 It follows that the rationale and factors applicable to both types of maintenance are different and that there could be no “identity of subject matter”.45 17.15

Notwithstanding that there was no issue estoppel, the Appellate

Division held that the HCF erred in ordering backdated former spousal maintenance for the wife. The wife argued that she was unemployed from

April 2021 to October 2024, the husband had the financial means to support her expenses, and that he had paid her a monthly allowance of

$6,000 from July 2021 to November 2021.46 The HCF’s main basis for the orders appeared to be that the wife was unemployed during the relevant period of the marriage and after divorce proceedings were commenced, thus engaging ss 69(1) and 113(1)(a) of the WC.47 However, interim maintenance and final spousal maintenance serve different purposes. In particular, former spousal maintenance is a broader remedy meant to even out economic disadvantages arising from the role the spouse undertook in the marriage and to achieve financial preservation in post-divorce life that realistically accounts for new realities that flow from the divorce.48

The power to order former spousal maintenance is supplementary to the division of matrimonial assets, and the court’s discretion will be exercised with regard to the objective of facilitating the former spouse’s transition 43

XHG v XHH [2025] 2 SLR 501 at [63].

XHG v XHH [2025] 2 SLR 501 at [66].

XHG v XHH [2025] 2 SLR 501 at [64]–[67].

XHG v XHH [2025] 2 SLR 501 at [16] and [67].

XHG v XHH [2025] 2 SLR 501 at [70]–[71].

XHG v XHH [2025] 2 SLR 501 at [72].

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25 SAL Ann Rev into post-divorce life where eventual economic self-sufficiency will be reasonably expected.49 17.16

Bearing the above principles in mind, it is only when an order for former spousal maintenance order is made under s 113(1)(b) of the

WC that the question of whether the orders should be backdated would arise.50 The Appellate Division made clear that the court had the power and discretion to backdate a final ancillary matters former spousal maintenance order. It referred to cases that affirmed the approach of backdating former spousal maintenance orders to periods prior to the ancillary matters hearing, so as to minimise the need for a wife to apply for interim maintenance pending the hearing of the final ancillary matters.51

The ancillary matters court’s discretion to backdate maintenance orders is in line with its broad powers to assess all available factors and evidence to ensure just financial and child-related outcomes for the family moving forward.52 17.17

Given that the HCF did not make any ancillary matters former spousal maintenance orders for the wife under s 113(1)(b), the Appellate

Division held that there was no basis to order backdated former spousal maintenance. The period prior to the ancillary matters hearing would have been relevant to interim spousal maintenance under s 69(1) and s 113(1)(a), which would then be subject to different legal considerations.

Without an order for ancillary matters former spousal maintenance, the court has no power under s 113(1)(b) to make only an award of backdated spousal maintenance covering earlier periods.53 17.18

Further, the wife’s unemployment alone was not a basis for ordering spousal maintenance. In addition to the spouses’ income, the court will weigh all relevant factors such as the parties’ other financial resources, their age and the length of the marriage. In the present case, the wife was awarded 47% of the matrimonial pool valued at $8.1m.

As the power to order former spousal maintenance under s 113(1)(b)

is supplementary to the power to divide matrimonial assets, the wife’s financial resources were relevant and ought to be considered.54 The

Appellate Division added that the wife would not have been successful in a claim for former spousal maintenance, given that she had worked throughout the marriage until April 2021, would receive a substantial share of matrimonial assets, and was gainfully employed and earning 49

XHG v XHH [2025] 2 SLR 501 at [73]–[74].

XHG v XHH [2025] 2 SLR 501 at [75].

XHG v XHH [2025] 2 SLR 501 at [76].

XHG v XHH [2025] 2 SLR 501 at [77]–[78].

XHG v XHH [2025] 2 SLR 501 at [79].

XHG v XHH [2025] 2 SLR 501 at [81].

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Family Law a substantial income at the time of the ancillary matters hearing.55 In light of the above, the Appellate Division set aside the HCF’s order of backdated spousal maintenance for the wife.

17.19

For completeness, the Appellate Division upheld the HCF’s indirect contributions ratio of 50:50. The Appellate Division applied the broad-brush approach and found that the broad factual indicators reflected a marriage where the husband made greater indirect financial contributions, whereas the wife made greater non‑financial contributions.56 The Appellate Division also declined to grant the husband’s request for a 3.5% uplift to his share of the matrimonial assets for the expenses he had to incur after he exited the matrimonial home in May 2022.57 The uplift would amount to approximately $283,000, which the husband claimed was close to the amount he spent on alternative accommodation.58 17.20

Rent-free occupation under s 112(2)(f) is one of the factors the court may take into account when exercising its powers to divide matrimonial assets in a just and equitable manner under s 112 of the

WC. The question was therefore whether the wife’s rent-free occupation of the matrimonial home with the children was a matter that should have an effect on the final ratio of division by adjusting the average ratio.59

The Appellate Division held that the words “rent-free occupation or other benefit enjoyed by” the occupying spouse in s 112(2)(f) suggested that this factor is focused on the benefit received by the occupying spouse, as opposed to compensating the excluded spouse for being excluded from the matrimonial home. The wife enjoyed the benefits of occupying the matrimonial home with the children to the exclusion of the husband.

That tied in with consideration of the needs of the children under s 112(2)(c), a factor relevant to the court’s exercise of power to divide matrimonial assets. After it became impracticable for the parties to live together, it was reasonable for the primary caregiver wife to remain in the matrimonial home with the children to maintain continuity of living and care arrangements in their best interests.60 55

XHG v XHH [2025] 2 SLR 501 at [83].

XHG v XHH [2025] 2 SLR 501 at [87]–[90].

XHG v XHH [2025] 2 SLR 501 at [106].

XHG v XHH [2025] 2 SLR 501 at [93].

XHG v XHH [2025] 2 SLR 501 at [95]–[98]. See also XML v XMM [2025] 5 SLR 241

at [175]–[182], where the Family Division of the High Court (“HCF”) awarded a 0.5% uplift to the average ratio after considering the wife’s rent-free occupation of the matrimonial home and other property-related matters.

XHG v XHH [2025] 2 SLR 501 at [100]–[103].

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25 SAL Ann Rev 17.21

Finally, the Appellate Division also upheld the HCF’s order against the husband for standard costs for the ancillary matters proceedings, and indemnity costs relating to the wife’s thrown-away costs for the husband’s belated disclosure of bank statements as a result of his breach of the duty of full and frank disclosure.61 It also awarded costs of $20,000 to the wife as she had been substantially successful in the appeal.62 17.22

The Appellate Division’s clarification in XHG on the interaction between the provisions governing interim maintenance and ancillary matters maintenance is very much welcome. When advising clients, practitioners stand guided by how the requirement of “neglect or refusal” to provide for reasonable maintenance applies for maintenance in a subsisting marriage under s 69(1) and interim maintenance during matrimonial proceedings under s 113(1)(a) to meet the wife’s immediate financial needs. On the other hand, former spousal maintenance under s 113(1)(b) serves the distinct purpose of evening out financial inequities arising from the roles adopted by the parties during the marriage and is supplementary to the division of matrimonial assets. The requirement of

“neglect or refusal” is therefore not required for this purpose.

17.23

XHG also paves the way for primary caregiver spouses, who tap on their existing resources to provide for the children during the relationship breakdown, to be subsequently recognised for their financial efforts. This is achieved through the backdating of any shortfall between the eventual quantum of reasonable child maintenance ordered and what the other party had in fact contributed during the relevant period.

Backdating minimises the need to apply for interim child maintenance where “neglect or refusal” has to be proven, yet ensures that both parties adequately contribute towards the children’s reasonable maintenance expenses prior to eventual orders being issued at the final ancillary matters hearing. Where the other party stopped contributing towards the children’s reasonable maintenance altogether, the court has wide powers to backdate reasonable maintenance from a fair date.63 Such an approach would minimise the number of interlocutory applications and hopefully reduce acrimony in divorce proceedings, in line with TJ.

17.24

The Appellate Division’s affirmation of the HCF’s “budget”

approach reflects a strong trend in the court’s stance towards child maintenance.64 As recently summarised by the HCF in WZF v WZG65 61

XHG v XHH [2025] 2 SLR 501 at [111]–[116].

XHG v XHH [2025] 2 SLR 501 at [117]–[118].

WZF v WZG [2025] 3 SLR 1219 at [124]–[126].

Lim Hui Min & Darren Chan, “Child Maintenance: Distinguishing Between

‘Reasonable Expenses’ and ‘Luxuries’” [2025] SAL Prac 31 at para 14.

[2025] 3 SLR 1219.

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Family Law

(“WZF”), the “budget” approach entails identifying broad categories of the child’s estimated needs and setting a corresponding reasonable sum for each category.66 It is the parties’ duty to exercise their shared parental responsibility, and not the province of the court, to determine how exactly the moneys should be expended.67 Parents are similarly exhorted by the principles of TJ to resolve these parenting issues in a co‑operative spirit over the years as the child’s needs change with age. It is expected that the parties co‑parent as a problem-solving team, instead of being entrenched in relitigation which prevents the family from moving forward with their lives. The HCF in WZF applied the “budget” approach by considering the relevant circumstances, such as the parent’s financial ability and what was reasonably necessary for the child, in ordering a total budget of $1,000

per month for the child’s enrichment68 and $1,900 for the child’s monthly reasonable household expenditure.69 17.25

Another significant case on maintenance is XFN v XFO70

(“XFN”), where the HCF affirmed the Family Court’s nominal maintenance order of $1 per month for the wife.71 The wife in XFN was a 39‑year-old Indian national and Singapore permanent resident (“PR”),72

whom the Family Court found had relocated to Singapore because of the marriage and lacked local family support.73 While the husband, wife and their daughter initially lived in the husband’s parents’ flat, the wife moved out in 2017 due to issues with her mother-in‑law.74 She moved into a Housing & Development Board (“HDB”) flat that the husband acquired during the marriage, and was later followed by the husband, his parents and their daughter.75 After a year, the husband and his parents left the HDB flat, taking the daughter with them.76 Thereafter in 2020, the husband petitioned the HDB to acquire the matrimonial flat despite the wife’s willingness to repay the mortgage loan and her actual payments of arrears in conservancy charges and loan instalments. As the husband did not consent to her payments, the HDB refunded all the wife’s payments in 2022 and she was evicted from the flat by HDB officers and police officers in 2024.77 66

WZF v WZG [2025] 3 SLR 1219 at [104].

WZF v WZG [2025] 3 SLR 1219 at [103]–[107].

WZF v WZG [2025] 3 SLR 1219 at [110].

WZF v WZG [2025] 3 SLR 1219 at [114].

[2025] SGHCF 29.

XFN v XFO [2025] SGHCF 29.

XFN v XFO [2025] SGHCF 29 at [1].

XFN v XFO [2025] SGHCF 29 at [8].

XFN v XFO [2025] SGHCF 29 at [2].

XFN v XFO [2025] SGHCF 29 at [3].

XFN v XFO [2025] SGHCF 29 at [4].

XFN v XFO [2025] SGHCF 29 at [5].

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