In Ong Jane Rebecca v Lim Lie Hoa and other appeals and other matters [2021] SGCA 63, the Singapore Court of Appeal held that the Riddick undertaking (i.e., the implied undertaking that a document disclosed during discovery will not be used for a collateral purpose) would apply to documents disclosed in examination of judgment debtor proceedings and clarified the principles regarding the use of such documents for purposes of related enforcement proceedings.
This case update examines the Court of Appeal’s decision.
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KOH Swee Yen
Partner – Commercial & Corporate Disputes
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e sweeyen.koh@wongpartnership.com
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LIN Chunlong
Partner – Commercial & Corporate Disputes
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e chunlong.lin@wongpartnership.com
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