TAN & AU LLP & Anor v GOH TEH LEE

[2025] SGHC 123 High Court (General Division) 1 July 2025 • HC/B 2246/2019 ( HC/SUM 3381/2024 ) • 26 min read

5 cases cited

Catchwords

Insolvency Law — Bankruptcy — Official Assignee’s certificate reducing the monthly contribution and target contribution under s 86D of the Bankruptcy Act — Whether Official Assignee can issue a new certificate in replacement of an earlier certificate — Whether certificate should be varied under s 86E of the Bankruptcy Act — Standard of review

Practice Areas

Insolvency Law

Judges (1)

Audrey Lim Delivered

Counsel (5)

Advocatus Law LLP Firm Insolvency & Public Trustee's Office Firm Lim Yew Jin Counsel Third Party Lim Yi Zheng Counsel Plaintiff Saadhvika Jayanth Counsel Plaintiff

Parties (4)

Official Assignee Third Party Tan & Au LLP Plaintiff Goh Teh Lee Defendant Tan Beng Hui Carolyn Plaintiff

Case Significance

[2025] SGHC 123 is a High Court (General Division) decision dated 1 July 2025 concerning Insolvency Law, specifically addressing bankruptcy. The judgment was delivered by Audrey Lim. The case was brought by Tan & Au LLP and others (plaintiff) against Goh Teh Lee (defendant). Legal representation was provided by Advocatus Law LLP. The judgment cites 5 cases and references 4 statutory provisions, including the Bankruptcy Act, the In the matter of the Bankruptcy Act, and the Insolvency.

Summary

A bankrupt applied to reduce his monthly contribution and target contribution set by the Official Assignee under s 86D(1) of the Bankruptcy Act, after the OA issued a replacement certificate correcting an earlier erroneous certificate. The court held the OA has power to issue a replacement certificate to correct errors, applied a standard of review examining whether the OA's decision was unreasonable or perverse, and reduced the monthly contribution from $100 to $50 given the bankrupt's age (68) and health conditions.

What was decided in [2025] SGHC 123?

[2025] SGHC 123 (TAN & AU LLP & Anor v GOH TEH LEE) is a High Court (General Division) decision from 1 July 2025 addressing Insolvency Law, specifically bankruptcy. The judgment was delivered by Audrey Lim.

Who were the parties in TAN & AU LLP & Anor v GOH TEH LEE?

The plaintiff in [2025] SGHC 123 was Tan & Au LLP, Tan Beng Hui Carolyn, and the defendant was Goh Teh Lee. Legal representation included Insolvency & Public Trustee's Office and Advocatus Law LLP. The case was decided on 1 July 2025 in the High Court (General Division).