XYY v XYZ

XYY v XYZ

The court applied the materiality test under P 9 r 4 of the FJ(G)R 2024 (as informed by Eng and Cachet) and held that requests must be properly identified and show a likely impact on the adjudicative outcome; the Wife's request in SUM 2891 failed for lack of proper identification and was unnecessary given the Husband had stated the vehicle's value in his affidavit (and must disclose supporting documents under P 9 r 3); the Husband's requests in SUM 2894 (Items 12,13,15,16) were not ordered but the Wife remains obliged under P 9 r 3 to disclose documents substantiating her ancillary matters allegations or to provide reasons for non-disclosure.

Citation
[2026] SGFC 17
Parties
Applicant (wife): XYY; Respondent (husband): XYZ
Court
Family Court
Jurisdiction
Singapore
Judgment Date
30 January 2026
Case Number
FC/OAD 356/2025 ( FC/SUM 2891/2025,FC/SUM 2894/2025 )
Procedural Posture
Family Law Divorce (ancillary Matters) / Hearing of Disclosure Applications and Reserved Decision
Outcome
No order for disclosure granted for the Wife's sole request in SUM 2891 due to improper identification and no need given affidavit disclosure; no order made in relation to the Husband's pursued items 12,13,15 and 16 in SUM 2894 but the parties remain bound by P 9 r 3 to disclose or give reasons; parties to file cost...
Legal Topics
Disclosure, Materiality Test, Ancillary Matters, Document Identification, Family Justice (general) Rules 2024
Source Language
English
Family Law Civil Procedure Evidence Disclosure Materiality Test Ancillary Matters Document Identification Family Justice (general) Rules 2024

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 4 Party arguments 2 Amounts and remedies 2
Sign in to unlock

Parties

XYY

Applicant (wife)

XYZ

Respondent (husband)

Procedural Posture

Family Law Divorce (ancillary Matters) / Hearing of Disclosure Applications and Reserved Decision

Legal Issues

  1. 1 What is the applicable test for disclosure under the FJ(G)R 2024 (materiality vs relevance/necessity)
  2. 2 Whether the Wife properly identified requested documents to meet P 9 r 4(1)(a) and (b)
  3. 3 Whether the Husband/Wife must disclose documents relied on in ancillary matters affidavits under P 9 r 3

Ratio Decidendi

The court applied the materiality test under P 9 r 4 of the FJ(G)R 2024 (as informed by Eng and Cachet) and held that requests must be properly identified and show a likely impact on the adjudicative outcome; the Wife's request in SUM 2891 failed for lack of proper identification and was unnecessary given the Husband had stated the vehicle's value in his affidavit (and must disclose supporting documents under P 9 r 3); the Husband's requests in SUM 2894 (Items 12,13,15,16) were not ordered but the Wife remains obliged under P 9 r 3 to disclose documents substantiating her ancillary matters allegations or to provide reasons for non-disclosure.

Court Disposition

No order for disclosure granted for the Wife's sole request in SUM 2891 due to improper identification and no need given affidavit disclosure; no order made in relation to the Husband's pursued items 12,13,15 and 16 in SUM 2894 but the parties remain bound by P 9 r 3 to disclose or give reasons; parties to file cost...

Orders

  • No order for disclosure in respect of the Wife's request in SUM 2891.
  • No order in relation to Items 12, 13, 15 and 16 in SUM 2894.