XXW v XXX and 5 other matters

XXW v XXX and 5 other matters

Court held that s 60A(1) is properly approached as a two‑stage inquiry: first establish that family violence has been committed or is likely to be committed (threshold), then assess necessity for a PPO via a risk assessment; both emotional/psychological and physical abuse are to be assessed by an objective reasonable‑person standard in context (with the victim’s characteristics admissible as context); intention/knowledge is not required but may inform context and necessity; applying those tests to the evidence, none of the six applications met the threshold and/or necessity and all were dismissed.

Citation
[2026] SGFC 23
Parties
Applicant and Respondent: XXW; Applicant and Respondent: XXX; Applicant and Respondent: XXY; Applicant and Respondent: XXZ
Court
Family Court
Jurisdiction
Singapore
Judgment Date
11 December 2025
Case Number
SSP 594/2025|SSP 443/2025|SSP 633/2025|SSP 505/2025|SSP 506/2025|SSP 634/2025
Procedural Posture
Personal Protection Order Applications Under Part 7 of the Women’s Charter 1961 / Hearing Concluded; Judgment Delivered (trial and Reserved Judgment)
Outcome
All six PPO applications dismissed
Legal Topics
Personal Protection Order (ppo), Definition of Emotional/psychological Abuse, Definition of Physical Abuse, Necessity Test for PPO, Risk Assessment, Relevance of Intention/knowledge
Source Language
English
Family Law Family Violence Statutory Interpretation Personal Protection Order (ppo) Definition of Emotional/psychological Abuse Definition of Physical Abuse Necessity Test for PPO Risk Assessment +1 more

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Parties

XXW

Applicant and Respondent

XXX

Applicant and Respondent

XXY

Applicant and Respondent

XXZ

Applicant and Respondent

Procedural Posture

Personal Protection Order Applications Under Part 7 of the Women’s Charter 1961 / Hearing Concluded; Judgment Delivered (trial and Reserved Judgment)

Legal Issues

  1. 1 Proper approach to s 60A(1) — sequential two‑stage (family violence then necessity) v necessity‑centred holistic approach
  2. 2 Standard of proof and standard of assessment for emotional/psychological abuse (objective v subjective v mixed)
  3. 3 Standard of assessment for physical abuse (objective v subjective v mixed)

Ratio Decidendi

Court held that s 60A(1) is properly approached as a two‑stage inquiry: first establish that family violence has been committed or is likely to be committed (threshold), then assess necessity for a PPO via a risk assessment; both emotional/psychological and physical abuse are to be assessed by an objective reasonable‑person standard in context (with the victim’s characteristics admissible as context); intention/knowledge is not required but may inform context and necessity; applying those tests to the evidence, none of the six applications met the threshold and/or necessity and all were dismissed.

Court Disposition

All six PPO applications dismissed

Orders

  • All six applications dismissed
  • Costs: parties to be heard on costs