Singapore Academy of Law Annual Review 2025: Equity and Trusts

22 October 2026

Allen & Gledhill Partner Tay Yong Seng co-authored the Equity and Trusts chapter of the 2025 Singapore Academy of Law Annual Review of Singapore Cases. The chapter encapsulates and evaluates equity and trust law decisions of the Singapore courts in 2025. The authors note that a recurring theme in the decisions in 2025 was the courts’ continuing reluctance to mechanistically apply the six-step framework in Chan Yuen Lan v See Fong Mun [2014] 3 SLR 1048 to common intention constructive trusts, with the courts instead preferring to ascertain the parties’ intentions, whether express or inferred, as the true determinant of beneficial ownership. This shift, reinforced by the landmark Court of Appeal decision in Wong Mei Lee Millie v Ngor Shing Rong Jake [2026] 1 SLR 600, reflects a broader judicial discomfort with rigid doctrinal tests in favour of a more fact-sensitive inquiry into the parties’ true intentions. Beyond disputes over family and matrimonial property, the courts also grappled with equitable remedies for fraud and misappropriation, most notably in Envy Asset Management Pte Ltd v Ng Yu Zhi [2025] 5 SLR 87, which examined the boundaries of fiduciary duty, dishonest assistance, and knowing receipt in the context of a Ponzi scheme.