WXW v WXX [2025] SGHC(A) 2

1          The parties were married in January 1988 and had 3 adult children at the time of the proceedings. The Judge of the Family Division of the High Court had determined that structured approach in ANJ v ANK [2015] 4 SLR 1043 did not apply to the division of the matrimonial assets in this case as this was a single-income marriage. The Wife appealed.

Court’s Decision:

2          The Court considered that, throughout the marriage, there was at least one helper employed, with two helpers employed at some periods as well. While it is possible for a homemaker spouse to have the assistance of domestic helpers and still be carrying out the role of a primary homemaker in a single-income marriage, the assistance of helpers can offer insights into how the household and caregiving responsibilities are carried out and hence may be relevant to determining the roles of the parties in the marriage.: at [21],[22].

3          The Husband was a present father who gave emotional support to the children and tended to their injuries, but the court observed that any father who is available at home at the material time would be expected to do so and that the main difference between the Husband and Wife was that the Husband had more time at home to spend with the children while the Wife had to find the time outside working hours to do so.: at [22].

4          The evidence suggested that the Husband was retrenched from his job in 1997, and did not resign voluntarily to be a homemaker and stay-at-home father to the children who were very young then. This was supported by his attempts at venturing into demanding businesses such as the laundry business and hawker business in the period following his cessation of full-time work. He was also incarcerated for 6 months in 2001, during which time the Wife managed the home and children single-handedly.: at [24],[25],[27].

5          Given the above considerations, the court was of the view that the Husband did not discharge a primary homemaking role. Instead, the parties shared homemaking responsibilities. The Husband also had a breadwinning role although he was not quite successful in that role. Hence, this was not a single-income marriage.: at [28].

The full text of the decision can be found here.

This summary is provided to assist the public to have a better understanding of the Court’s judgment. It is not intended to be a substitute for the reasons of the Court. All numbers in bold font and square brackets refer to the corresponding paragraph numbers in the Court’s judgment.