CRAPPER IAN ANTHONY v SALMIZAN BIN ABDULLAH

Case Significance

Crapper Ian Anthony v Salmizan bin Abdullah [2024] SGCA 21 was decided by the Court of Appeal of Singapore on 28 June 2024, with Steven Chong JCA delivering the grounds of decision of the court, sitting with Sundaresh Menon CJ and Debbie Ong Siew Ling JAD (Civil Appeal No 31 of 2023, heard 9 May 2024). The matter began as a relatively modest personal injury claim commenced before the Magistrate's Court. The appellant and respondent had agreed to enter a consent interlocutory judgment at 90 per cent in favour of the respondent, while "leaving the issues of damages and causation to be assessed", because the appellant disputed the causal connection between the accident and the respondent's injuries.

The court recorded that during the assessment of damages hearing, a Deputy Registrar of the State Courts, drawing on the court's earlier decision in Tan Woo Thian v PricewaterhouseCoopers Advisory Services Pte Ltd [2021] 1 SLR 1166, raised concerns over whether the parties could lawfully enter interlocutory judgment with an express reservation as to causation of the claim for general damages. In light of those concerns, the appellant applied to transfer the case to the General Division of the High Court to seek a pronouncement. The case engaged the Supreme Court of Judicature Act and the State Courts Act. Counsel included Tan Chin Hoe & Co for the appellant, Ling & Ling LLC for the respondent, and Cavinder Bull of Drew & Napier LLC as independent counsel.