Singapore hosts many expatriate families, often for a few years. Its English-inspired family law in the Women’s Charter may divide assets very differently from French law. Court choice and timing matter greatly.
An initial overview, not a consultation
This page outlines Singapore law and its connections with French law. It is an initial overview, not a consultation: every situation depends on specific facts and local law changes. For each case, I work with a colleague based in Singapore, who confirms these initial details for your circumstances and acts before local courts when necessary.
0 — Your situation
You live in Singapore and one spouse wants to return to France. You are French, married to a Singaporean. Your spouse began proceedings there. A parent left with the child. This page covers civil marriages under the Women’s Charter; Muslim marriages have separate legislation and courts.
1 — Which court?
In Singapore. Either spouse must be domiciled there at filing or habitually resident during the immediately preceding three years. Residence must be voluntary and stable; long absences can interrupt continuity. No application may be made during the first three marriage years without court permission.
Parallel proceedings. Singapore courts may stay for a more appropriate forum under forum non conveniens. French courts may, without obligation, defer if the future Singapore judgment can be recognized in France.
2 — Which law?
Before the Singapore court. The court applies Singapore law.
3 — Recognition
In Singapore. No bilateral divorce-recognition convention exists. A French judgment is recognized under common-law rules, notably if issued by the court of either spouse’s domicile, subject to public policy.
Divorce without a judge. No Singapore decision has addressed French divorce signed by lawyers. Rules designed for judgments create a real risk. If a spouse lives or owns assets there, a French judicial divorce approving the agreement is safer.
After a French divorce. Following a divorce recognized in Singapore, a spouse domiciled there or habitually resident for a year may, with prior court permission, seek property division or maintenance if Singapore is the appropriate forum.
4 — Your relationship
Divorce in Singapore. Irretrievable breakdown is established by one of six facts: adultery, behavior, two years’ desertion, three years’ separation with consent or four without, and since 1 July 2024, mutual agreement. Written agreement must explain breakdown reasons, reconciliation attempts and proposed child and financial arrangements.
Maintenance after divorce. It may be awarded to a former wife and, in certain cases, a former husband unable to support himself.
5 — Your children
The 1980 Hague Convention has applied with France since 1 January 2012. For wrongful removal of a child under sixteen, immediate return may be sought in the Family Justice Courts under the International Child Abduction Act 2010. The central authority is the Ministry of Social and Family Development. Singapore is not party to the 1996 Convention: French residence decisions are not automatically recognized and often need a local order.
The court treats child welfare as the first and paramount consideration, with equal parental rights. Relocation has no presumption favoring the primary parent. Loss of the other parent’s connection is important but not decisive. The other parent’s consent or court permission is required.
6 — Your assets
Property division. Matrimonial assets, including those abroad, are divided justly and equitably. Courts generally compare direct financial contributions, then indirect contributions including homemaking and child care, average them and adjust. Premarital, donated or inherited assets are generally excluded unless used as the family home or substantially improved during marriage.
Marriage agreements. A French agreement is considered and may carry substantial or decisive weight, but does not bind the court. It may be set aside for fraud or unfairness; children’s clauses do not bind the judge.
Singapore courts may divide French assets. For Singapore citizens or permanent residents, compulsory CPF retirement savings, including those used for the family home, form part of divisible assets. These funds serve division rather than maintenance, and orders must meet CPF Board requirements. French courts liquidate property under their own rules: comparing outcomes is often decisive.
Singapore is not party to the 2007 Convention. Simplified foreign-maintenance enforcement under the Maintenance Orders (Reciprocal Enforcement) Act 1975 applies only to designated countries, excluding France. A French maintenance judgment generally requires Singapore proceedings.
Points to watch
Both three years of marriage and, without domicile, three years of habitual residence are needed before filing.
Neither the 1996 nor the 2007 Hague Convention applies between France and Singapore.
French separate-property agreements are not applied automatically.
Non-recognition of French non-judicial divorce may also bar financial claims in Singapore.
7 — My support
An international consultation compares French and Singapore options, preferably before court filing. My Singapore colleague confirms local-law analysis and acts locally. Negotiation or international family mediation in French or English seeks an agreement designed for both countries.
Official texts and sources
International Child Abduction Act 2010
Guardianship of Infants Act 1934
Maintenance Orders (Reciprocal Enforcement) Act 1975
Singapore Courts: requirements for divorce
Singapore Courts: BNS v BNT [2015] SGCA 23
Ministry of Social and Family Development: central authority
Hague Conference: status of the 1980 Child Abduction Convention