The Singapore High Court has ruled that a Hong Kong judgment obtained by Venetian Macau Limited (VML) against a casino patron cannot be enforced in Singapore. The court found that doing so would conflict with the country’s public policy on the enforcement of gambling debts.
The dispute involved Venetian Macau Limited, a major subsidiary of Sands China that owns and operates The Venetian Macao integrated resort, which obtained a default judgment from Hong Kong's Court of First Instance against casino patron Hu Yangning in March 2025 over approximately HK$19.35m (US$2.47m) in unpaid casino credit. The company later sought to register and enforce the judgment in Singapore under the Reciprocal Enforcement of Foreign Judgments Act (REFJA).
Hu challenged the registration on several grounds, including public policy, lack of notice, fraud and jurisdiction.
In a judgment delivered on September 4, Justice Philip Jeyaretnam held that the registration must be set aside because enforcing the Hong Kong judgment would be contrary to Singapore’s statutory public policy against the enforcement of gambling debts.
The court found that Section 5(2) of Singapore’s Civil Law Act, which bars actions to recover gambling debts, reflects a continuing legislative policy that also applies when courts are asked to recognize and enforce foreign judgments founded on such debts.
The judgment also distinguished an earlier Court of Appeal decision involving the now-repealed Reciprocal Enforcement of Commonwealth Judgments Act, concluding that the previous ruling was not binding because it was based on a different statutory framework.
While Hu succeeded on the public policy issue, the court rejected her remaining arguments. Justice Jeyaretnam found that she had received sufficient notice of the Hong Kong proceedings, that there was no evidence the Hong Kong judgment had been obtained through fraud and that the Hong Kong court had jurisdiction based on the agreements she signed with the casino.
As a result, the High Court allowed Hu’s appeal in part, set aside the registration order and awarded her costs, while leaving the underlying Hong Kong judgment unaffected outside Singapore.
The case clarifies how Singapore’s Reciprocal Enforcement of Foreign Judgments Act applies to foreign judgments based on gambling debts
