Singapore High Court Blocks Enforcement Of Foreign Casino Debt

In a ruling that could have significant implications for how and when casinos across Asia issue credit to high rollers, the Singapore High Court has determined that a gambling debt accrued in another jurisdiction cannot be enforced in Singapore, even when a foreign judgment rules it enforceable.

Read more AFL

The case was brought by Sands China subsidiary Venetian Macau Ltd against a woman named Hu Yangning, who in 2023 entered into a credit agreement with Venetian for up to HK$15 million (US$1.9 million) and signed a promissory note in relation to money advanced for gambling.

After Hu failed to repay the money owed, Venetian sued her in Hong Kong and in March 2025, received a default judgment from the Court of First Instance, High Court of Hong Kong, requiring her to pay a total of HK$19.35 million plus 18% interest and costs.

Enforcement Sought In Singapore

Venetian then sought to pursue assets held by Hu in Singapore and registered the Hong Kong judgment under Singapore’s Reciprocal Enforcement of Foreign Judgments Act 1959, which provides a mechanism for enforcing certain court judgments from other countries in Singapore.

However, after Hu appealed, Singapore’s High Court on Friday ruled that enforcing a gambling debt through a Singapore court would violate the country’s longstanding public policy under the Civil Law Act, which prevents such action, even when the gambling itself was lawful and took place at a licensed foreign casino.

Promissory Note Ruling

Notably, Judge Philip Jeyaretnam found that the promissory note itself did not provide a distinction between a gambling debt and any other form of contractual debt because of the underlying nature of the debt, meaning the promissory note was inextricable from the arrangement that allowed Hu to gamble at the Macau casino.

The court also rejected an important precedent presented in the case, Liao Eng Kiat v Burswood Nominees Ltd [2004] SGCA 45, in which the Singapore Court of Appeal had allowed enforcement of an AU$50,000 (US$35,000) debt accrued by a player at the Burswood casino (now Crown Perth) in Australia

Precedent And Framework Changes

In doing so, Judge Jeyaretnam pointed out that the Burswood ruling was made under the old Reciprocal Enforcement of Commonwealth Judgments Act rather than the current REFJA framework, while referencing another case, Poh Soon Kiat v Desert Palace Inc [2010] 1 SLR 1129, which criticized the reasoning used in the Burswood case and suggested it should be reviewed if the issue rose again.

Read more PAS Calls For Federal Review Of Gambling License Policy

Importantly, the Singapore High Court ruling did not deem that Hu does not owe the money, nor does it invalidate the Hong Kong judgement or prevent Venetian Macau Ltd from pursuing enforcement in other jurisdictions.

Regional Implications

But it could still have widespread implications for the region, particularly in how casinos approach the issuance of debt to Singapore-based customers or those who hold their assets in Singapore, as has become common for wealthy individuals in the region.

Interestingly enough, the Marina Bay Sands casino belongs to the group of the most famous resorts, where its owner, Las Vegas Sands (LVS), also has the majority stake in Sands China and, in turn, Venetian Macau Ltd.

LVS only last week increased its stake in Sands China to 75.01%.

Credit Issuance Considerations

The ruling places new considerations on how casinos issue credit to high rollers who may hold assets in Singapore. The decision affects the enforcement of foreign casino debts through Singapore courts, even when the gambling was lawful and took place at a licensed foreign casino.

The court’s reasoning focused on the underlying nature of the debt and the inextricable link between the promissory note and the gambling arrangement. The rejection of the Burswood precedent under the current REFJA framework adds further weight to the decision.

Enforcement Options Remain

Venetian Macau Ltd retains the ability to pursue enforcement in other jurisdictions, as the Singapore ruling does not invalidate the Hong Kong judgment. The decision limits enforcement options in Singapore while leaving other avenues open.

This situation demonstrates the intricacies of enforcing the debts of gamblers who use the services of international casinos, as well as the importance of public policies in affecting court decisions.

Read more NRL

Source: Inside Asian Gaming