Singapore Insurance Law Round-up (April – June 2026)
A round up of our social media posts tracking developments in Singapore insurance law from April to June 2026.
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A Recent Lesson from Hong Kong for Singapore Motor Insurers
Motor insurers in Singapore have a statutory liability to pay certain injury related claims even when they have a policy liability defence such a drink driving. Accordingly, motor insurers often join suits as interveners so that they can control their exposures by putting Claimants to strict proof of their claim. Having obtained a judgment, the insurer may then seek to recover their outlay from the assured.
The recent Hong Kong case of QBE HongKong & Shnaghai Insurance Ltd v Wong Man Hin Max [2026] HKDC 577 caught our attention.
HK based motor insurers also have a statutory liability to cover injury claims at first instance.
What is interesting about the case is that the motor insurer settled the injury claim at mediation. QBE then commenced proceedings against their policyholder for recovery of the settlement sum.
The HK District Court reviewed the settlement sum and awarded QBE a judgment sum which was slightly lower than the mediated settlement.
Also, the court considered whether QBE had waived its policy defences by repudiating late in the day. The Court held that there was no waiver. The defendant had not pleaded any. representation by QBE, whether by words or conduct during the negotiations, which was capable of inducing him to act to his detriment, let alone any alteration of his position in reliance on the representation.
An “Insurer concerned” under the MIB agreement acts as MIB’s agent for the purposes of the MIB Agreement
In Lim Chai Hing v Motor Insurers’ Bureau of Singapore and others [2026] SGHC 41, the Claimant was injured in a road traffic accident. He obtained judgment against the driver of the other car (Mr Pang), which was a rental car. But, unbeknownst to Mr Pang, the hire company was not the owner of the car and had not insured the car. Rather, the hire company had itself hired the vehicle from a second rental company.
The second rental company had an insurance policy written by Lberty. However, the policy excluded sub-leasing situations. It therefore did not cover Mr Pang’s accident.
There being no insurance in play, the Claimant could look to the Motor Insurers’ Bureau (MIB) if the judgment sum against Mr Pang went unpaid.
Liberty was not off the hook. Liberty is a signatory of the MIB Agreement and therefore had agreed to cover certain judgment sums even when its policy was not engaged.
Liberty requested that the Claimant add in the two hire companies as Co-Defendants as condition precedent for Liberty paying the judgment sum. This was on the basis that these companies (separately or together) owed a duty to insure the vehicle for Mr Pang’s use. This would allow Liberty to seek recovery from the hire companies.
The request was not heeded by the Claimant. This was fatal. The District Court and High Court both held that Liberty was the “insurer concerned” under the MIB Agreements and in making the request Liberty acted as MIB’s agent. Since the request was worded as a condition precedent and the request was not heeded, Liberty did not need to pay the sum.
When does time start to run for enforcing an arbitral award?
The Court of Appeal in South of England Protection and Indemnity Association (Bermuda) Limited v Pacmar Shipping Pte Ltd (2026) SGCA 20 has clarified that the limitation period begins when the award debtor fails to honour the award, not simply from the date the award is issued.
Courts treat enforcement of an award as an independent cause of action, based on the implied promise to comply.
In practice, since awards are usually payable immediately upon issuance, the date of breach and the date of the award often coincide.
This approach ensures clarity and certainty, preventing debtors from delaying liability until they explicitly refuse payment.
👉 Takeaway: For most cases, the clock starts ticking the moment an award is issued and not complied with. This reinforces the importance of acting promptly when enforcing arbitral awards.
Appellate Division confirms that multipliers in the Actuarial Tables may be further discounted to take into account vicissitudes of life other than early death
Mr Lim sustained serious brain injuries as a result of a chain collision involving three motor vehicles in Malaysia. He was the front seat passenger in the vehicle in the middle of the chain. His wife as Personal Representative sued the driver and owner of the car that Mr Lim was travelling in together with the other motorists involved.
In Low Woon Hong v Lim Chun Yong (alias Lin Junxiong) (suing through his deputy and litigation representative Fung Wui Mang Janet) and other appeals [2026] SGHC(A) 4
The General Division awarded the wife $4,700,960.28 (100% basis) and apportioned liability between the first to fifth Defendants. The award included $1,595,146.72 for loss of income.
Various appeals were filed, including an appeal on how the loss of earnings award was calculated. The Appellants argued that the Judge had been too generous in his projection of Mr Lim’s loss of future employment. This was because Mr Lim had a checkered employment history and therefore there was uncertainty as to whether he would have remained in the same job for the balance of his working life (but for the accident). The Appellants sought a 30% reduction, saying that there was a real likelihood that Mr Lim would have left the job and would have had periods of unemployment.
At [34] the Appellate Divisions held “We agreed with the Appellants that discounting the Judge’s award for loss of future earnings by 30% was warranted in light of the uncertainties associated with Mr Lim’s future employment. Having regard to Mr Lim’s chequered employment history, we were of the view that there was significant uncertainty as to whether Mr Lim would have been employed at the SAS or in a role offering similar remuneration in the long term until the age of retirement.”
This is a decision that insurers should note.
Proposed Legal And Regulatory Framework For Autonomous Vehicles
The Ministry of Transport (MOT) has commenced a public consultation to gather feedback on the proposed legal and regulatory framework for autonomous vehicles (AVs) in Singapore.
Another Costs Order for Misciting Cases - Goh Chin Cheng v Choco Up SG Pte Ltd [2026] SGHCR 13
In this recent case, the claimant was seeking to set aside a statutory demand. His written submissions (prepared by counsel) miscited passages from two authorities: Sheagar and City Hardware Pte Ltd v Kenrich Electronics Pte Ltd [2005] 1 SLR(R) 733 ("City Hardware").
The claimant's counsel admitted that the quotes used were inaccurate during a hearing on 21 January. Later he clarified that some of the errors were due to his reliance on case summaries and principles that he had come across in his online research.
The court ordered him to pay $900 in costs for the errors.
For the full story see paragraphs 77 to 100 of the grounds of decision.
Formation of SPF Cyber Command
CNA Online reported on May 11th that “the Singapore Police Force (SPF) will establish a new unit in July that will consolidate its counter-scam and cybercrime capabilities.
Known as the SPF Cyber Command, it will be a frontline unit with about 200 officers across operations, investigations and intelligence. Two targets of the Cyber Command are scam and cybercrime syndicates.
As one of the world’s most digital societies with close to 96 per cent internet usage and as a high-trust society, Singapore is an attractive target for scammers, Minister of State for Home Affairs, Goh Pei Ming, said.
There were 37,308 scam cases last year, down from the 51,501 cases recorded in 2024.
Mr Goh warned that the fight against scams is far from over.
"Criminals are constantly evolving, and with the use of technology, including AI, they can reach victims with speed and at scale," he said.
"A recent report by Interpol found that fraud enabled by AI can be up to 4.5 times more profitable than traditional methods.”
PM Wong "Singapore’s laws and institutions must evolve and keep pace in age of AI"
In a speech at the SGLaw200 Youth Forum, the PM touched on issues which have an insurance law angle. He pondered “When an AI system causes harm – a wrong medical diagnosis, a fatal accident involving a self-driving car – who should be held accountable? “The developer who built it? The one who wrote the algorithms? The company that deployed the machine? Or the person who used it?”
This will be an area of great legal development in the coming years. This will push insurance issues to the forefront.
High Court: there is a general entitlement to production of documents referred to in affidavits - eSave AG v eSave APAC Pte Ltd and another [2026] SGHCR 17
A dispute arose between eSave AG and its joint venture partner, eSave APAC Pte Ltd, over whether the latter had the right to use the “eSave” trademark independently, after it allegedly installed lighting products without the claimant’s core components for HDB projects.
Following exchange of AEICs, the Claimant sought production of documents mentioned in the AIEC. AR Elton Tan allowed the application. The core reasons:
At [38] “ If a party refers to a document in his affidavit, he is in the ordinary course relying on that document to support his version of events. In other words, the document is part of, or at least bears out, his version of events. This must be the case if the account of events in his affidavit is not simply to be a bare assertion. Given the likely relevance of the document to the dispute and its potential significance to the drafting party’s case, fairness and parity calls for its disclosure to the counterparty. With that document in hand, the counterparty will be in a better position to evaluate the drafting party’s account of events and explain whether it agrees or disagrees with that account.”
At [39] and[40] this is in line with the ‘cards on the table’ approach and the goals of the 2021 Rules is that “disputes are resolved on the factual and legal merits”.
He then set out a general approach to applications for production of documents referred to in pleadings and affidavits under the 2021 Rules. This is summarised at [76]. A key issue is that production may be opposed if there is ‘good cause’.
On the facts, AR Tan ordered production of the “tender proposal to the HDB on 2 March 2023” and the production of the contract that the 1st Defendant entered into with the HDB or EM Services Pte Ltd, in respect of the HDB Project 2023.
Why do lawyers keep citing fake cases invented by AI?
According to Scientific American it is because AI appears to inspire a particular kind of trust. Warnings about AI accuracy don't seem to be working, perhaps because such warnings compete with advertising that highlights the technology’s potential and with workplace pressures to use it to save time.
Man forged Medical Invoices to get S$12,000 in Claims From Company Insurer, Gets Jail
The Straits Times reported that over a 2 year period, Bhutra Ravi forged medical invoices over 57 occasions to obtain more than S$12,000 (US$9,300) in medical reimbursement from his company’s healthcare insurer.
Ravi pleaded guilty to one charge of cheating, with another three charges taken into consideration. He was sentenced to 20 weeks’ jail.
A rare decision mentioning the order 5 duty to Offer Amicable Resolution and a reminder that an OAR should contain an element of compromise – Nirmala d/o Thangavellu v Acestes Pte Ltd [2026] SGDC 195
This costs decision flowed from an earlier decision in which the Claimant’s personal injury claim against the Defendant was dismissed.
The Defendant sought costs, relying on an Offer of Amicable Resolution made before trial. However, the Judge declined to recognize the offer as triggering a costs award in the Defendant’s favour. This was because the terms of the offer stated that the Claimant shall discontinue the action and pay the Defendant’s costs and disbursements. The judge held that under this offer the Claimant was to yield fully. In the words of the judge such an offer was “the antithesis of a compromise” because it lacked any element that would induce or facilitate settlement and cannot be considered a “genuine” offer (citing Singapore Airlines Ltd and anor v Fujitsu Microelectronics (Malaysia) Sdn Bhd and others [2001] 1 SLR(R) 38 at [10] and [11]). The judge also opined that it was hard to tell how the offer’s terms are more favourable to the Claimant than the judicial outcome.
Protected Cell Company – a New Corporate Structure for the Insurance Sector?
Singapore is thinking of introducing a new corporate structure for the insurance sector called the protected cell company (PCC), and speed up approvals for new categories of investment funds, in fresh measures to bolster the financial sector.
The proposed framework aims to support the growth of alternative risk transfer solutions like insurance-linked securities.
The framework will likely be introduced through a new statute as well as consequential amendments to the Insurance Act 1966.
Changes to the Retirement and Re-employment Ages
A reminder to lawyers computing loss of earnings claims, from 1 July 2026, the statutory retirement age in Singapore is now 64 and the re-employment age is now 69. This will increase settlement sums.