Abstract:
This article examines the Appellate Division’s observations in United Overseas Bank Ltd v Lippo Marina Collection Pte Ltd [2026] SGHC(A) 21 on the proper basis for awarding pre-judgment interest. In particular, it considers whether interest must invariably be calculated on the final net judgment sum, or may instead run on a larger gross amount before later recoveries or deductions are taken into account. The article examines s 12 of the Civil Law Act 1909 (2020 Rev Ed) and para 6 of the First Schedule to the Supreme Court of Judicature Act 1969 (2020 Rev Ed), contrasts the Singapore and English positions, and considers the practical significance of the court’s observations for future claims for interest.