High Court holds in Great Eastern Financial Advisers Private Limited v Lim Siang Heng [2026] SGHC 203 that a sum remains 'liquidated' under s 311(1)(b) of the IRDA even where quantification requires extrinsic facts and non-arithmetical processes.

The court rejected the narrow view that a liquidated sum must be ascertainable by mere arithmetic from the contract itself. Instead, the true test is whether the sum can be ascertained by a complete process of quantification without judicial assessment, regardless of whether the formula or underlying facts are extrinsic to the agreement. This overturned the assistant registrar's approach that had set aside a statutory demand for clawed-back commissions.

Why it mattersPractitioners can now issue statutory demands for debts requiring factual investigation beyond the contract's four corners, provided the quantification process is complete and does not need judicial evaluation.