HU YINAN V PEH CHIN HUA & 2 ORS

HU YINAN V PEH CHIN HUA & 2 ORS

Production under ROC 2021 requires showing materiality to the issues (not mere relation to pleaded facts); where a list of documents is accompanied by copies under O 11 r 2, production is limited to the copies actually provided with the list and inspection under O 11 r 12 is confined to originals of those produced documents; parties must be specific when describing classes of documents; where native export is impossible, authentication may be ordered by foreign lawyers' comparison and affidavit.

Citation
[2026] SGHC 103
Parties
Claimant: Hu Yinan; First Defendant: Peh Chin Hua; Second Defendant: White Group Pte Ltd; Third Defendant: Michael ET Chan
Court
General Division of the High Court
Jurisdiction
Singapore
Judgment Date
14 May 2026
Case Number
HC/OC 150/2025 ( HC/RA 1/2026,HC/RA 2/2026 )
Procedural Posture
Originating Claim No 150 of 2025 / Registrar's Appeals (hc/ra 1/2026; Hc/ra 2/2026)
Outcome
RA 1 allowed in part; RA 2 allowed with variation to AR's order; costs each party to bear their own costs.
Legal Topics
Production of Documents, Inspection of Documents, List of Documents, Scope of Disclosure, Cross Border Inspection and Authentication
Source Language
English
Civil Procedure Evidence Electronic Evidence Production of Documents Inspection of Documents List of Documents Scope of Disclosure Cross Border Inspection and Authentication

Case Brief

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Parties

Hu Yinan

Claimant

Peh Chin Hua

First Defendant

White Group Pte Ltd

Second Defendant

Michael ET Chan

Third Defendant

Procedural Posture

Originating Claim No 150 of 2025 / Registrar's Appeals (hc/ra 1/2026; Hc/ra 2/2026)

Legal Issues

  1. 1 Whether documents that relate to facts pleaded are automatically producible
  2. 2 Proper interpretation and effect of Order 11 r 2 and Order 11 r 12 of ROC 2021 on scope of production
  3. 3 Whether requested documents were identified with sufficient particularity

Ratio Decidendi

Production under ROC 2021 requires showing materiality to the issues (not mere relation to pleaded facts); where a list of documents is accompanied by copies under O 11 r 2, production is limited to the copies actually provided with the list and inspection under O 11 r 12 is confined to originals of those produced documents; parties must be specific when describing classes of documents; where native export is impossible, authentication may be ordered by foreign lawyers' comparison and affidavit.

Court Disposition

RA 1 allowed in part; RA 2 allowed with variation to AR's order; costs each party to bear their own costs.

Orders

  • Allowed HC/RA 1/2026 except as to amended category 2; ordered first and second defendants to file an affidavit in response to amended category 2.
  • Allowed HC/RA 2/2026 and varied the Assistant Registrar's order: inspection limited to originals of only the documents that the claimant provided with CLOD2 in respect of C008 to C010.