Singapore Restructuring & Insolvency Yearbook 2025

© WongPartnership LLP DISCLAIMER: This update is intended for your general information only. It is not intended to be nor should it be regarded as or relied upon as legal advice. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein. WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships Act 2005. CASEWATCH JANUARY 2026 Singapore Restructuring & Insolvency Yearbook 2025 2025 has been yet another prolific year for the development of Singapore restructuring and insolvency case law. In this update, we highlight ten of the most significant decisions in 2025 and discuss their implications for the restructuring and insolvency landscape in Singapore. These decisions span a wide range of topics, including cross-border restructuring (forum shopping, arbitration vs insolvency, enforcement of stay orders), schemes of arrangement (classification, restructuring of business trusts), liquidation / judicial management (removal of officeholders, information gathering powers) and proofs of debt (adjudication, expungement, “double dipping”). We also invite you to revisit our Singapore Restructuring & Insolvency Yearbook 2024 and Singapore Restructuring & Insolvency Yearbook 2023. CASE NAME / TOPIC DISCUSSION Re Fullerton Capital Ltd (in liquidation) [2025] 1 SLR 432 (Fullerton Capital) (Cross-border restructuring – COMI – Forum shopping) When seeking recognition of a foreign restructuring or insolvency proceeding, a key issue is determining the location of the centre of main interests (COMI) of the company in question. If the foreign restructuring or insolvency proceeding is taking place in the company’s COMI, the proceeding will be recognised as a main proceeding, which is afforded enhanced reliefs and greater deference than a non-main proceeding under the UNCITRAL Model Law on CrossBorder Insolvency (Model Law). Prior to Fullerton Capital, lower court decisions held that the COMI test only considered activities of the company while it was “alive and flourishing”, and activities undertaken while the company was undergoing the foreign proceeding were irrelevant. Overruling the earlier decisions, the Court of Appeal in Fullerton Capital held that activities undertaken while the company is undergoing the foreign proceedings can be considered, with such activities weighed against the historical operational activities of the company on a sliding scale of relevance. Practical takeaway: This decision is significant in the cross-border restructuring and insolvency context, as it enables a company undergoing foreign restructuring and insolvency proceedings to fortify its connections to the jurisdiction in which the foreign proceedings are ongoing, for example by administering the business and operations, engaging in restructuring negotiations with creditors and raising funds within that jurisdiction. This in turn increases the likelihood that such proceedings would be recognised as a main proceeding if recognition is later sought in Singapore. It particularly gives greater comfort and certainty for companies seeking to implement a “COMI shift” (a recognised practice in complex cross-border restructuring cases), which involves shifting the company’s COMI to a jurisdiction that can facilitate a value-enhancing restructuring that benefits its creditors and stakeholders. The Court of Appeal affirmed that cases of good “forum shopping” are unobjectionable, while cases of bad “forum shopping” Restructuring & Insolvency © WongPartnership LLP DISCLAIMER: This update is intended for your general information only. It is not intended to be nor should it be regarded as or relied upon as legal advice. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein. WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships Act 2005. CASEWATCH JANUARY 2026 CASE NAME / TOPIC DISCUSSION can be weeded out by ascribing the proper weight to the activities undertaken in the foreign jurisdiction depending on the specific circumstances of each case. Sapura Fabrication Sdn Bhd and others v GAS and another appeal [2025] 1 SLR 492 (Sapura) (Cross-border restructuring – Arbitration vs insolvency) Sapura concerns the tension between: (a) enforcing international arbitration agreements (party autonomy); and (b) the collective character of restructuring proceedings (giving the debtor company “breathing space” to put forward a restructuring proposal). In particular, it deals with whether a creditor should be allowed a “carve‑out” from a restructuring moratorium to pursue its claim in arbitration instead of through the restructuring proof / adjudication process. In deciding whether a carve-out should be allowed, the courts consider several factors such as: (a) the timing of the application for a carve-out; (b) the nature of the claim; (c) existing remedies; (d) the merits of the claim; (e) the existence of prejudice to the creditors or to the orderly administration of the restructuring proceedings; and (f) other miscellaneous factors such as the potential of an avalanche of litigation being unleashed by the grant of permission, the proportionality of the cost of the proceeding to the scheme company’s resources, and the views of the majority creditors. The Court of Appeal affirmed the lower court’s decision to grant the carve-out for the arbitration to proceed, primarily because the claims involved were factually complex (involving heavily disputed construction-contract termination / delay claims requiring detailed factual and expert evidence) and impracticable for an adjudicator to meaningfully adjudicate within the scheme process. Practical takeaway: In Singapore, a restructuring / insolvency moratorium does not automatically defeat an arbitration agreement; but neither does the existence of an arbitration agreement create an entitlement to proceed in arbitration. The question remains whether the court should grant a carve-out in its discretion, applying the balancing exercise mentioned above. For more details, read our update, Insolvency and the Arbitration Agreement – Another Chapter Unfolds in Sapura Fabrication Sdn Bhd v GAS. Re Terraform Labs Pte Ltd [2025] 3 SLR 1516 (Terraform Labs) (Cross-border restructuring – Recognition – Enforcement of stay order) Terraform Labs was one of the most high-profile cross border restructuring and insolvency cases before the Singapore International Commercial Court (SICC) since the SICC opened its doors to restructuring and insolvency matters in 2022. Terraform Labs was the creator of the Terra blockchain protocol and algorithmic stablecoin TerraUSD and sister token LUNA. In the aftermath of a multi-billion dollar securities fraud claim brought by the US Securities and Exchange Commission (SEC), Terraform Labs filed for bankruptcy under Chapter 11 of the US Bankruptcy Code. Following a jury verdict in favour of the SEC, Terraform Labs entered a settlement with the SEC and formulated a Chapter 11 liquidation plan for the orderly wind down of the company, the creation of a wind down trust, and the distribution of recoveries to its creditors (including creditors who suffered crypto losses due to the Terra-Luna collapse). © WongPartnership LLP DISCLAIMER: This update is intended for your general information only. It is not intended to be nor should it be regarded as or relied upon as legal advice. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein. WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships Act 2005. CASEWATCH JANUARY 2026 CASE NAME / TOPIC DISCUSSION The Terraform Labs cases in Singapore related to the recognition and implementation of the Chapter 11 liquidation plan in Singapore. The cases were heard by SICC International Judge James Michael Peck (a former US Judge in the Bankruptcy Court for the Southern District of New York who presided over some of the most complex Chapter 11 cases in US history). In the first case, the SICC reiterated that the court’s discretion to grant “any appropriate relief” under article 21(1) of the Model Law is expansive and open-ended, with any such relief capable of being fashioned and formulated based on the demonstrated needs of each case. The court recognised the Chapter 11 plan, authorised the administration and realisation of the Singapore-located assets in accordance with the plan and imposed a stay on proceedings in respect of compromised claims. The stay barred all proceedings being brought against the company, except for the “Beltran Action” (a representative action brought by crypto claimants in Singapore) which had been carved out by the plan. In the second case, certain claimants against the company sought to join in the Beltran Action. Their motive for doing so was to improve their position under Terraform Labs’ Chapter 11 plan, as the plan gave the claimants in the Beltran Action the right to recover from an escrow fund if they succeeded in the action. The SICC held that the joinder application was filed in defiance of an explicit injunction prohibiting the commencement of claims and cautioned that “[f]uture instances of interference with recognition orders will expose any parties who take unjustified actions to costs awards, especially in cases such as this one where the adverse impact on the foreign debtor and its assets is directly related to a wilful violation of a court order meant to afford protections to the foreign debtor and to facilitate implementation of its restructuring plan”. Practical takeaway: The Terraform Labs decisions underscore the sanctity of recognition and stay orders and the SICC’s strict stance against intentional violations of such orders. More broadly, the case also demonstrates how the SICC is a prime forum for handling complex cross-border restructuring and insolvency cases given its bench of renowned international judges. For more details, read our update, SICC Gives Guidance on the Grant of “Any Appropriate Relief” under Article 21(1) of the Singapore Model Law. UT Singapore Services Pte Ltd v Goh Thien Phong and others and another appeal [2025] 1 SLR 687 (Scheme of arrangement – Classification) The liquidators of Hin Leong Trading (Pte) Ltd (presiding over one of the largest trade finance fraud cases in Singapore) proposed a scheme of arrangement to make an interim pari passu distribution of US$80m (obtained from the sale of oil which was subject to multiple competing claims by creditors). The scheme involved compromising creditors’ claims to potential security rights that were uncertain and subject to pending interpleader proceedings and related applications. This facet of the scheme was particularly unique (compared to debt restructuring schemes), as what was being schemed was not a security right per se, but a claim to such a security right. The Court of Appeal held that the proper “appropriate comparator” was not an insolvent liquidation scenario, but instead the scenario of proceeding with a determination of security claims, with all the time, trouble, and expense which that entailed. The scheme therefore permissibly classified all the potential secured creditors in a single class because, in the comparator and under the scheme, their relative positions were sufficiently similar. Each © WongPartnership LLP DISCLAIMER: This update is intended for your general information only. It is not intended to be nor should it be regarded as or relied upon as legal advice. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein. WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships Act 2005. CASEWATCH JANUARY 2026 CASE NAME / TOPIC DISCUSSION potential secured creditor faced material uncertainty as to validity and priority of any security, as well as the costs, delay and litigation risk of full adjudication. Practical takeaway: This case demonstrates the flexibility and utility of the scheme of arrangement in Singapore, and its potential usefulness in cases involving indeterminate and complex claims that may be costly and time consuming to litigate, conceivably encompassing mass tort, product liability and investor fraud claims. Re Dasin Retail Trust Management Pte Ltd [2025] 4 SLR 1346 (Dasin Retail Trust) (Restructuring – Scheme of arrangement – Business trust) Dasin Retail Trust is the first case in Singapore involving a listed business trust seeking to restructure its debts through a scheme of arrangement under the Companies Act 1967. Although the scheme of arrangement regime under the Companies Act 1967 applies only to companies (not business trusts), Dasin Retail Trust confirms that a business trust can in substance be restructured through a scheme of arrangement proposed by the business trust’s trustee-manager. The trustee-manager, which is ordinarily a company, can use a scheme to restructure the debts which it has incurred on behalf of the business trust in its capacity as the contracting obligor / debtor for the trust’s financing. Practical takeaway: Dasin Retail Trust is a welcome decision as it opens the gateway for real estate investment trust (REIT) debt restructurings in Singapore. However, there are potential limitations with the approach used in that case (of having the trustee-manager propose a scheme of arrangement). The majority of REITs in Singapore are constituted as unit trusts under trust deeds (rather than business trusts), and rather than having a special purpose vehicle serving as its trustee-manager, these REITs often have a licensed trust company serve as its trustee. It may be infeasible for such licensed trust companies (which are often divisions within larger financial institutions) to propose a scheme of arrangement for various commercial reasons. In our article, When Singapore REITs go under: risks and solutions for lenders, we explore potential structures that can be used to overcome such issues to synthetically restructure or wind up a REIT. Zhu Su v Three Arrows Capital Ltd and others and other appeals [2025] 1 SLR 968 (Three Arrows) (Cross-border insolvency – Liquidator / Judicial manager’s information gathering powers) Section 244 of the Insolvency, Restructuring and Dissolution Act 2018 (IRDA) is a useful statutory provision which allows a liquidator or judicial manager to apply for court orders to compel certain persons to produce documents and information concerning the promotion, formation, business, dealings, affairs or property of the company. Three Arrows highlights several key principles which define the ambit of section 244 of the IRDA: (a) Unlike its predecessor provision in the Companies Act 1967, section 244 of the IRDA does not require a person first to be summoned to court before he can be made to submit an affidavit or produce documents; (b) When a disclosure order under section 244 of the IRDA is made against a corporate entity and the corporate entity fails to comply with the order, the officers of that entity can be found personally liable for contempt of court if they caused the entity to fail to comply with the order; © WongPartnership LLP DISCLAIMER: This update is intended for your general information only. It is not intended to be nor should it be regarded as or relied upon as legal advice. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein. WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships Act 2005. CASEWATCH JANUARY 2026 CASE NAME / TOPIC DISCUSSION (c) Relatedly, the officers of the corporate entity from whom documents and information are sought may themselves be made personally subject to the disclosure order; and (d) If a liquidator or judicial manager has formed an intention to sue a person whom he is seeking to examine, the courts would usually not grant an examination order to avoid giving the liquidator or judicial manager an unfair advantage in the contemplated litigation. Practical takeaway: The information gathering powers under section 244 of the IRDA are a valuable tool in an insolvency officeholder’s toolkit, especially since it can enable disclosure and examination orders to be made against the officers of a corporate entity and prevent them from hiding behind the corporate veil. However, an insolvency officeholder cannot rely on the disclosure and examination regime once he has formed an intention to sue the person from whom he is seeking to obtain disclosure or to examine. Tay Lak Khoon v Tan Wei Cheong (as Judicial Manager of USP Group Ltd) and Others [2025] 2 SLR 118 (Liquidation / Judicial management – Removal of liquidator / judicial manager) The Court of Appeal clarified that the test for determining whether a liquidator or judicial manager should be removed is whether it is in the “real and substantial interest” of the liquidation or judicial management. When applying the test, the court will weigh all relevant factors, such as: (a) The views of all stakeholders who have an interest in the liquidation (which will be the creditors in insolvency scenarios); (b) The stage of the insolvency process and the incumbent officeholder’s familiarity with the company (generally, the more advanced the liquidation or judicial management, the more compelling the reasons must be for removal, because removal will be disruptive to the insolvency process and the estate will be burdened with additional costs for the replacement officeholder to familiarise himself with the affairs of the company); and (c) Where errors were made in good faith and did not cause prejudice to the insolvency process, removal might not be appropriate. Further, the Court of Appeal held that where the party seeking to remove the officeholder is alleging that the officeholder is biased, it is not sufficient or pertinent that the party subjectively believes that the officeholder is biased. The test is whether a fair-minded and informed objective party would reasonably apprehend bias in light of the nature of the decisions, the circumstances and the context. In obiter, the Court of Appeal also expressed some reservations about the lower court’s decision to discount the votes of related party creditors on the judicial managers’ statement of proposals by analogy to scheme of arrangement voting principles. The Court of Appeal noted important differences between a scheme of arrangement and a judicial manager’s statement of proposals and left open whether related party votes should be discounted in the latter scenario. © WongPartnership LLP DISCLAIMER: This update is intended for your general information only. It is not intended to be nor should it be regarded as or relied upon as legal advice. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein. WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships Act 2005. CASEWATCH JANUARY 2026 CASE NAME / TOPIC DISCUSSION Practical takeaway: The Court of Appeal’s clarification of the test for removal should give a measure of comfort for insolvency officeholders who are acting honestly and diligently, particularly as the Court of Appeal has clarified that the mere subjective belief of bias does not suffice to show due cause for removing an insolvency officeholder. For more details, read our update, Judicial Managers and “Due Cause”: Court of Appeal Consolidates Removal Threshold in Tay Lak Khoon v Tan Wei Cheong. Yit Chee Wah and another v Inner Mongolia HuomeiHongjun Aluminium Electricity Co, Ltd and another appeal [2025] 1 SLR 1110 (Yit Chee Wah) (Liquidation – Proof of debt – Expungement / Reduction) In Yit Chee Wah, the liquidator of a company initially admitted a proof of debt but later discovered evidence which called into question the validity of the debt. The liquidator applied to the court to seek an expungement of the proof of debt under rule 133(1) of the Insolvency, Restructuring and Dissolution (Corporate Insolvency and Restructuring) Rules 2020. In a landmark decision, the Court of Appeal laid out a two-stage test for the expungement or reduction of a proof of debt. First, at the threshold stage, the liquidator must show reasonable grounds for thinking that the proof was improperly admitted (in the sense that it was admitted by mistake) and that but for that mistake the proof would have been rejected. The liquidator is not required at this stage to prove, on a balance of probabilities, that the debt is in fact invalid. Second, once that threshold is met, the court moves to the merits stage, where it must decide the actual validity and quantum of the claimed debt. At this stage, it is the creditor who bears the burden of proving the validity of the debt. Importantly, the test laid down by the Court of Appeal is more favourable to liquidators (compared to the test applied by the lower court) as it places the burden on the creditor to prove the validity of its debt rather than on the liquidator to disprove the validity of the debt. Practical takeaway: This decision provides valuable guidance for insolvency practitioners navigating complex or evolving factual patterns. The Court of Appeal’s approach enables liquidators to make timely adjudications based on the evidence presently available, with the option to apply to the court for expungement if evidence subsequently emerges that casts serious doubt on the admitted claims. For more details, read our update, Singapore Court of Appeal Clarifies Test for Expungement or Reduction of Proofs of Debt in Insolvency Proceedings. Shim Wai Han v Lai Seng Kwoon (in his capacity as the joint and several trustee of the bankruptcy estate of Ng Yu Zhi) and another [2025] 4 SLR 876 (Liquidation – Proof of debt – Double dipping) This case arose out of a fraudulent nickel trading scheme perpetrated by the “Envy” group of companies and its founder Ng Yu Zhi (NYZ). A victim of the fraud filed a proof of debt in the bankruptcy of NYZ, based on alleged tort of deceit and/or (unlawful / lawful means) conspiracy, arising from alleged fraudulent representations by NYZ inducing her to invest in the Envy companies. The trustee in bankruptcy rejected the proof of debt, arguing that the claim ought to be filed in the liquidations of the Envy companies to avoid the claimant receiving double recovery of her claims. © WongPartnership LLP DISCLAIMER: This update is intended for your general information only. It is not intended to be nor should it be regarded as or relied upon as legal advice. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein. WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships Act 2005. CASEWATCH JANUARY 2026 CASE NAME / TOPIC DISCUSSION The court, however, held that it was permissible for the claimant to file claims against both NYZ’s bankruptcy estate and the Envy companies’ liquidation estates (a practice known as “double dipping”), and held that the potential for double recovery did not affect the substantive validity of the claims. The court noted that issues such as avoiding double recovery could be managed later in the dividend process, such as by updating the proofs of debt if the claimant receives dividends from any of the insolvent estates. Practical takeaway: This case affirms the right of a claimant to file overlapping claims against insolvent estates (i.e., “double dip”), and enables a claimant to pursue multiple avenues of recourse in an insolvency situation. For more details, read our update, Should Proofs of Debt be Rejected Simply Because of Complexity or Parallel or Overlapping Claims Across Different Insolvent Estates?. Park Hotel Group Management Pte Ltd v Aw Eng Hai (in his capacity as a joint and several liquidator of Park Hotel CQ Pte Ltd (in liquidation)) and others [2025] SGHC 97 (Park Hotel) (Liquidation – Proof of debt – Adjudication) Park Hotel involved a rare case of a creditor challenging the liquidator’s admission of another creditor’s proof of debt. The General Division of the High Court set out several key principles in relation to such a challenge: (a) Where a bona fide challenge is brought by a disputing creditor regarding the admission of a proof of debt of another creditor, the liquidator must satisfy the court on a balance of probabilities that he/ she had adjudicated the proof of debt properly; (b) The liquidator should support his / her decision with a proper basis and be prepared to defend it when it is challenged; and (c) When a liquidator’s decision to admit a proof of debt is challenged before the court, the liquidator has a duty to explain how he / she came to the decision to admit each claim in the proof of debt with reference to specific documents supporting that claim and how the quantum of that claim was computed. Practical takeaway: Park Hotel is a helpful reminder to insolvency officeholders that they exercise a quasi-judicial function when adjudicating proofs of debt, and should be prepared to provide reasons and support for their adjudications. If you would like information and/or assistance on the above or any other area of law, you may wish to contact the Partner at WongPartnership whom you normally work with or any of the following Partners: Smitha MENON Head – Restructuring & Insolvency Partner – Special Situations Advisory d: +65 6416 8129 e: smitha.menon @wongpartnership.com Click here to view Smitha’s CV. Lionel LEO Partner – Restructuring & Insolvency and Special Situations Advisory d: +65 6517 3758 e: lionel.leo @wongpartnership.com Click here to view Lionel’s CV. © WongPartnership LLP DISCLAIMER: This update is intended for your general information only. It is not intended to be nor should it be regarded as or relied upon as legal advice. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein. WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships Act 2005. CASEWATCH JANUARY 2026 Joel CHNG Partner – Restructuring & Insolvency and Special Situations Advisory d: +65 6517 8707 e: joel.chng @wongpartnership.com Click here to view Joel’s CV. Clayton CHONG Partner – Restructuring & Insolvency and Special Situations Advisory d: +65 6416 2472 e: clayton.chong @wongpartnership.com Click here to view Clayton’s CV. Daniel LIU Partner – Restructuring & Insolvency and Special Situations Advisory d: +65 6416 2470 e: zhaoxiang.liu @wongpartnership.com Click here to view Daniel’s CV. TAN Kai Yun Partner – Restructuring & Insolvency and Special Situations Advisory d: +65 6416 6869 e: kaiyun.tan @wongpartnership.com Click here to view Kai Yun’s CV. Adnaan NOOR Partner – Restructuring & Insolvency and Special Situations Advisory d: +65 6416 2477 e: adnaan.noor @wongpartnership.com Click here to view Adnaan’s CV. Eden LI Partner – Restructuring & Insolvency and Special Situations Advisory d: +65 6517 3766 e: eden.li @wongpartnership.com Click here to view Eden’s CV. Muhammed Ismail NOORDIN Partner – Restructuring & Insolvency and Special Situations Advisory d: +65 6517 3760 e: muhammedismail.konoordin @wongpartnership.com Click here to view Ismail’s CV. WPG MEMBERS AND OFFICES - [email protected] SINGAPORE - WongPartnership LLP 12 Marina Boulevard Level 28 Marina Bay Financial Centre Tower 3 Singapore 018982 t +65 6416 8000 f +65 6532 5711/5722 CHINA - WongPartnership LLP Shanghai Representative Office Unit 1015 Link Square 1 222 Hubin Road Shanghai 200021, PRC t +86 21 6340 3131 f +86 21 6340 3315 INDONESIA - Makes & Partners Law Firm Menara Batavia, 7th Floor Jl. KH. 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