Loss Of Inheritance Or Savings

Always revitalising and evolving



About the project

The Singapore Academy of Law’s Law Reform Committee recommended that the Civil Law Act (Chapter 43, 1999 Revised Edition) should be amended to allow a court to take into account a loss of savings or loss of inheritance in a dependency claim in the tort of negligence, thus reversing the position taken by the High Court in Lassiter Ann Masters (suing as the widow and dependant of Lassiter Henry Adolphus, deceased) v To Keng Lam (alias Toh Jeanette) (No 2) [2005] SGHC 4, [2005] 2 Singapore Law Reports [SLR] 8. The Committee was of the view that the position taken by the Lassiter case was unsatisfactory as it created a gap which benefited tortfeasors or their insurers at the expense of dependants. There was a need to bring Singapore law back in line with the more persuasive position taken by the other common law jurisdictions which have legislation expressly allowing for loss of savings or inheritance to be taken into account in a dependency claim.

Project status: Completed

  • The report was published in April 2008.
  • Parliament implemented the report’s recommendation in the Civil Law (Amendment) Act 2009 (No 7 of 2009), which was passed on 19 January 2009 and came into force on 1 March 2009, by inserting a new section 22(1A) into the Civil Law Act.
  • The report was cited by the Court of Appeal to interpret section 22(1A) of the Civil Law Act in Zhu Xin Chun (alias Myint Myint Kyi) v Rockwills Trustee Ltd (administrators of the estate and on behalf of the dependants of Heng Ang Tee Franklin, deceased) [2016] SGCA 52, [2016] 5 SLR 412 at paragraph 89.

Areas of law

 Tort law


Click on the image above to view the report

Last updated 6 June 2019



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