Singapore court upholds validity of marriage of convenience — Channel NewsAsia

Singapore’s Court of Appeal dismissed an appeal by the son of the late Chan Meng Koon, who sought to have his father’s 2011 marriage to Vietnamese national Dang Lan Anh declared invalid. According to Channel NewsAsia, because the man died without a will, his wife may claim half of the estate.

Majority decision

The deceased’s son, Chan Chee Chuen, asked for the marriage to be declared a sham and for Dang Lan Anh to be barred from inheriting. Two of the three Court of Appeal judges — Debbie Ong and Ang Cheng Hock — concluded that the court could not declare a marriage invalid on grounds not provided for in Singapore’s Women’s Charter.

The judges noted that motives that may be considered improper were not a separate ground for annulling a marriage. Legislative amendments under which marriages of convenience entered into from October 1, 2016, are void cannot be applied to a marriage entered into in 2011.

Chief Justice Sundaresh Menon issued a dissenting opinion. In his view, the marriage should have been declared invalid because it had not been entered into on the basis of a valid marriage licence within the meaning of the legislation. However, this position remained in the minority.

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Circumstances of the case

Chan Meng Koon married Dang Lan Anh on January 26, 2011. As established by the court, he did not inform his family about the marriage, did not live with his wife and continued to live with his sister. Before the marriage, the man had financial difficulties and was harassed by loan sharks.

Less than a year after the marriage, Chan Meng Koon died of cancer. The family learned about the marriage in March 2012 from a letter from the Office of the Official Assignee and Public Trustee. In July 2024, the immigration service informed the family that Dang Lan Anh had been deported for violating immigration law back in 2011.

The deceased’s assets mainly consisted of his 14% share in a Housing Board flat and funds in the Central Provident Fund. At the same time, the Court of Appeal did not make a separate ruling on the administration or distribution of the estate, as this issue was not considered as part of the appeal.