XWB v XWC

XWB v XWC

On the balance of probabilities the Father’s words and conduct, when viewed in context and given evidential gaps, did not amount to 'emotional or psychological abuse' under s58B(4) because they lacked the necessary coercive control, were contextual to sibling disputes, did not cause demonstrable mental harm or fear in C or the Mother, and the evidential shortcomings (incomplete CCTV/audio, absence of C’s testimony) undermined the Applicant’s case; consequently PPOs and ancillary orders were not warranted.

Citation
[2025] SGFC 135
Parties
Applicant (mother): XWB; Respondent (father): XWC
Court
Family Court
Jurisdiction
Singapore
Judgment Date
15 December 2025
Case Number
HCF/DCA 134/2025
Procedural Posture
Personal Protection Order Under the Women’s Charter (family Violence) / Trial Judgment (applications Dismissed by District Judge Janice Chia); Appeal Filed by Applicant
Outcome
Both Personal Protection Order applications (for the Mother and for child C) dismissed.
Legal Topics
Personal Protection Order, Emotional and Psychological Abuse, Coercive Control, Evidentiary Rules (browne V Dunn), Standard of Proof in Family Proceedings
Source Language
English

Case Brief

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Parties

XWB

Applicant (mother)

XWC

Respondent (father)

Procedural Posture

Personal Protection Order Under the Women’s Charter (family Violence) / Trial Judgment (applications Dismissed by District Judge Janice Chia); Appeal Filed by Applicant

  1. 1 Whether the Father’s conduct constituted "emotional or psychological abuse" under s58B(4) of the Women’s Charter as against the Mother and child C
  2. 2 Whether a Personal Protection Order and ancillary relief were necessary for protection or safety
  3. 3 Whether evidential deficiencies (incomplete CCTV/audio, absence of child witness) precluded a finding of family violence

Ratio Decidendi

On the balance of probabilities the Father’s words and conduct, when viewed in context and given evidential gaps, did not amount to 'emotional or psychological abuse' under s58B(4) because they lacked the necessary coercive control, were contextual to sibling disputes, did not cause demonstrable mental harm or fear in C or the Mother, and the evidential shortcomings (incomplete CCTV/audio, absence of C’s testimony) undermined the Applicant’s case; consequently PPOs and ancillary orders were not warranted.

Court Disposition

Both Personal Protection Order applications (for the Mother and for child C) dismissed.

Orders

  • PPO applications in SSP 623/2025 and SSP 722/2025 dismissed
  • Costs awarded to Respondent in the sum of 450.0 (SGD)