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In United Overseas Bank Ltd v Lippo Marina Collection Pte Ltd [2026] SGHC(A) 21, the Appellate Division considered an important question concerning pre-judgment interest: where damages are ultimately awarded as a net figure, must interest be calculated on that net figure from the outset, or can interest run on a larger gross amount for an earlier period before recoveries, realised security or other deductions reduce the claimant’s entitlement? 

The decision provides useful guidance on the interaction between section 12 of the Civil Law Act 1909 (“Section 12”) and Paragraph 6 of the First Schedule to the Supreme Court of Judicature Act, and the circumstances in which the Court may award pre-judgment interest on sums that do not ultimately form part of the final judgment sum. 

A key takeaway is that pre-judgment interest serves a compensatory purpose, reflecting the fact that a successful claimant has been kept out of money to which it is ultimately shown to be entitled. The Appellate Division observed that Section 12 does not necessarily confine the Court to awarding interest only on the final net judgment sum. 

Read our full article here.