SINGAPORE Trends and Developments Contributed by: Kee Lay Lian, Yoon Min Joo, Shawn Teo and Joshua Daniel Foo, Rajah & Tann Singapore
A Practitioners’ Guide to Filing and Resisting International Child Relocation Applications in Singapore In our most recent editions of this chapter, we charted the evolution of the law on international child reloca - tion in Singapore – from the primacy of the custodial parent’s wishes in the Re C era, through the recalibra - tion in BNS v BNT [2015] 3 SLR 973 (BNS), and into the holistic, child-centric, multifactorial framework that now governs relocation applications following TSF v TSE [2018] 2 SLR 833 (TSF) and WRU v WRT [2024] SGHCF 23 (WRU). We observed that the assessment continues to be very much a child-centric enquiry, prioritising the welfare of the child, as determined through a multifactorial enquiry, and that this is in line with, and shaped by, Therapeutic Justice. In this instalment, we move from principle to prac - tice. Drawing on the trends and developments from decided cases and the Family Justice Courts Therapeutic Justice Model (the “TJ Model”), we present a practitioners’ guide that distils key practical takeaways, good practices, and “dos and don’ts” for lawyers filing or resisting reloca - tion applications. The Governing Framework The overriding consideration in every relocation appli - cation is the child’s welfare and best interests. The assessment is an objective one that eschews any pre-fixed precedence or hierarchy among factors, categorical pigeonholes that predetermine outcomes, and any presumption for or against relocation. These are simply factors to be weighed alongside all other relevant considerations (BNS at [20] – [22]; XUL v XUM [2025] SGFC 123 (XUL) at [8]). In this regard, the court’s analytical framework broadly considers (XUL at [9] – [13]): • the reasons for relocation and whether they are genuine, rational and coherent; • the impact of relocation on the child, including inte - gration in Singapore, attachments, and the availa - bility of concrete plans to minimise disruption; and • the child’s views, where appropriate.
It may also be observed that the courts have consid - ered more specific relevant factors, including, but not limited to, the following: • the wishes of the parents; • loss of relationship with the left-behind parent;
• the age of the child; • connecting factors; • immigration status; • family support; • the parenting plan; • post-relocation access; and • the child’s developmental needs. Please refer to the
2024 edition the Child Relocation Trends & Develop - ments chapter of this guide for a detailed explanation. Practical Considerations – Filing a Relocation Application Prepare a detailed and concrete relocation plan The importance of a well-considered relocation plan cannot be overstated. As Debbie Ong JC (as she then was) noted in TAA v TAB [2015] 2 SLR 879 (TAA) (at [20]) “The law will not permit hastily made unilateral plans that fail to consider the welfare of the children. But well made plans that promote both the common interests of the parent and the children can be sup - ported”. In WRU, the court noted favourably that the mother had prepared a detailed and measured relocation plan incorporating concrete steps to ensure the children’s stability. She was able to demonstrate secured liv - ing arrangements, research into schooling, and the financial security of the reconstituted family (at [21]). Conversely, in XII v XIJ [2025] 5 SLR 470 (XII (HC)) (at [37] – [39]), the court found the mother’s plan “largely speculative” and “unsupported by concrete arrange - ments” where she had not secured employment and her proposals for accommodation and education were based on supposition. Please refer to the 2025 edition of the Child Relocation Trends & Devel - opments Chapter of this guide for a detailed explana - tion on XII (HC).
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