The Court of Appeal (CA) has articulated a “modern approach” to resulting trusts in Wong Mei Lee Millie v Ngor Shing Rong Jake [2026] SGCA 27, reiterating that the available evidence of the transferor’s intention must first be analysed before any recourse is had to presumptions. The CA observed that, in an age of comprehensive digital records (including e-mails, text messages, and other contemporaneous documentation), such evidence will rarely be unavailable, relegating the presumptions of resulting trust and advancement to tools of last resort.

The CA also addressed, in obiter comments, the legal consequences of co-owners buying property in a 99:1 ratio. It expressed the tentative observation that such arrangements may, in certain circumstances, give rise to tax evasion. Where this is the case, denying a resulting trust claim would not, in the CA’s view, be a disproportionate response to the illegality.

To view our update on the decision, please click here.

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:

Josephine CHOO
Head – Specialist & Private Client Disputes
d +65 6416 8120
e josephine.choo@wongpartnership.com
Click here to view Josephine’s CV.

Vincent HO
Partner – Specialist & Private Client Disputes and Private Wealth
d +65 6416 6878
e vincent.ho@wongpartnership.com
Click here to view Vincent’s CV.