SGHCF holds in [2026] SGHCF 25 that a catch-all allocative clause in a consent order, which merely assigns assets already belonging to a party without identifying specific assets or imposing positive obligations, is insufficiently clear and unambiguous to found committal proceedings for contempt.
The court applied the principle from Iberian Trust and Mok Kah Hong that a sine qua non for contempt is that an order must state in unambiguous terms what the defendant must do. Paragraph 2 merely assigned assets already belonging to a party; it did not identify specific assets, resolve ownership disputes, or impose a positive obligation to deliver the dogs within a specific timeframe. This lack of clarity mirrored UNE v UNF, and thus the clause could not support committal.
Why it mattersPractitioners seeking to enforce consent orders through contempt must draft precise, positive obligations with specific deliverables and timeframes; broad allocative clauses will not support committal even if breached.