Lau Yean Liang, Raymond v JASON ALEKSANDER KARDACHI & Anor

[2025] SGCA 11 Court of Appeal 13 March 2025 • CA/CA 28/2024 ( CA/SUM 31/2024 ) • 99 min read
54 cases cited (41 SG, 13 foreign) Cited by 2 cases

Catchwords

Practice Areas

Judges (3)

Counsel (7)

Parties (4)

Case Significance

[2025] SGCA 11 is a Court of Appeal decision dated 13 March 2025 concerning Insolvency Law, specifically addressing cross-border insolvency. The judgment was delivered by Steven Chong, with Judith Prakash and Kannan Ramesh on the coram. The case was brought by Lau Yean Liang, Raymond (appellant) against Elaine Hanrahan and others (respondent). Legal representation was provided by Sreenivasan Chambers LLC and Setia Law LLC. The judgment cites 54 cases (41 Singapore, 13 foreign) and references 6 statutory provisions, including the English Insolvency Act, the Evidence Act, and the Insolvency. This decision has been cited by 2 subsequent judgments in the dataset.

[2025] SGCA 11 explained

Lau Yean Liang, Raymond v JASON ALEKSANDER KARDACHI & Anor ([2025] SGCA 11) is a Singapore judgment decided by the Court of Appeal on 13 March 2025. It is categorised under Insolvency Law. Within this corpus it has since been cited by 2 other reported Singapore judgments, a measure of how often later decisions have referred to it. This page summarises what the reported decision covers and links the primary sources — the full judgment, the statutes it cites, and the other cases it engages with — so the decision can be read in context. It is reference information, not legal advice, and it does not state the outcome or any holding beyond what the official judgment records.

What is [2025] SGCA 11 about?

Lau Yean Liang, Raymond v JASON ALEKSANDER KARDACHI & Anor ([2025] SGCA 11) is a Court of Appeal decision from 2025. Its published catchwords are “Insolvency Law — Cross-border insolvency — Disclosure and examination orders — Whether disclosure and examination orders unreasonable, oppressive or unnecessary”, “Insolvency Law — Cross-border insolvency — Allegation of bad faith and material non-disclosure against foreign representatives — Whether recognition would be contrary to public policy — Art 6 UNCITRAL Model Law on Cross-Border Insolvency”, and “Insolvency Law — Cross-border insolvency — Recognition of foreign insolvency proceedings — Presumption of COMI as place of registered office — Effect of presumption — Whether presumption rebutted on the balance of probabilities — Art 16(3) UNCITRAL Model Law on Cross-Border Insolvency”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.

Which legislation does [2025] SGCA 11 consider?

The judgment refers to English Insolvency Act, Evidence Act (Cap 97), Insolvency, Restructuring and Dissolution Act, and Interpretation Act (Cap 1), among other provisions. The statutes cited are listed in full on this page, each linking to its primary text.

What earlier Singapore cases does [2025] SGCA 11 cite?

Among the in-corpus authorities it refers to are [2025] SGHC(I) 5, [2025] SGHC 31, and [2024] SGHC 302, and 2 more. The complete list of cases cited, and of later cases that cite this decision, is shown on this page.

How influential is [2025] SGCA 11?

Within this corpus, [2025] SGCA 11 has been cited by 2 later reported Singapore judgments. That count reflects references from other decisions held in this corpus only and is a conservative lower bound on how often the case has actually been cited.

Summary

Raymond Lau appealed against a court order recognising the BVI liquidation of Fullerton Capital Limited as foreign main proceedings under the UNCITRAL Model Law and granting disclosure and examination orders against him. The key issues were whether Fullerton's centre of main interests (COMI) was in the BVI or Singapore, whether the foreign representatives acted in bad faith, and whether the disclosure orders were oppressive. The Court of Appeal dismissed the appeal, holding the COMI presumption at the place of registration was not rebutted and the public policy exception was not engaged.

What was decided in [2025] SGCA 11?

[2025] SGCA 11 (Lau Yean Liang, Raymond v JASON ALEKSANDER KARDACHI & Anor) is a Court of Appeal decision from 13 March 2025 addressing Insolvency Law, specifically cross-border insolvency. The judgment was delivered by Steven Chong.

Who were the parties in Lau Yean Liang, Raymond v JASON ALEKSANDER KARDACHI & Anor?

The appellant in [2025] SGCA 11 was Lau Yean Liang, Raymond, and the respondent was Elaine Hanrahan, Jason Aleksander Kardachi. Legal representation included Setia Law LLC and Sreenivasan Chambers LLC. The case was decided on 13 March 2025 in the Court of Appeal.

Which judge decided [2025] SGCA 11?

[2025] SGCA 11 was delivered by Steven Chong in the Court of Appeal on 13 March 2025. Judith Prakash and Kannan Ramesh also sat on the coram. The case concerned Insolvency Law.

What cases and statutes does [2025] SGCA 11 cite?

[2025] SGCA 11 cites 54 prior decisions, including 13 from foreign jurisdictions. It references English Insolvency Act, Evidence Act, Insolvency. The decision has itself been cited by 2 subsequent judgments.

Statutes Cited

Cases Cited (54)

SLR (33)
[1992] 1 SLR(R) 912 [1995] 2 SLR(R) 900 [1997] 3 SLR(R) 649 [2002] 1 SLR(R) 1136 [2005] 3 SLR(R) 263 [2006] 1 SLR(R) 582 [2008] 4 SLR(R) 543 [2008] 4 SLR(R) 994 [2010] 1 SLR 286 [2010] 3 SLR 1007 [2011] 1 SLR 391 [2012] 4 SLR 250 [2013] 4 SLR 308 [2014] 3 SLR 1161 [2014] 4 SLR 500 [2015] 3 SLR 665 [2017] 2 SLR 265 [2018] 2 SLR 159 [2018] 5 SLR 125 [2019] 2 SLR 341 [2019] 2 SLR 372 [2019] 4 SLR 1343 [2020] 1 SLR 1296 [2020] 1 SLR 226 [2020] 2 SLR 695 [2023] 2 SLR 421 [2023] 3 SLR 1333 [2023] 3 SLR 250 [2023] 4 SLR 1575 [2024] 1 SLR 361 [2024] 2 SLR 317 [2024] 3 SLR 254 [2025] 1 SLR 19
UK (13)
[1954] 1 WLR 1489 [1970] AC 913 [1985] 1 WLR 948 [2006] Ch 508 [2011] Ch 33 [2015] EWHC 3778 [2020] EWHC 2090 [2021] 1 WLR 2498 [2021] EWHC 3346 [2022] AC 995 [2023] EWHC 2205 [2024] 3 WLR 659 [2024] EWHC 3399

Cited By (2)

Referenced in

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGCA 11)