A Singapore High Court ruling has stopped Venetian Macau Ltd from enforcing a HK$19.35 million (US$2.5 million) gambling debt against a VIP customer whose assets are held in Singapore.
The September 4 decision involved Hu Yangning, a businesswoman who had been a VIP customer at Marina Bay Sands in Singapore. According to evidence considered by the court, a client manager at the Singapore resort introduced Hu to The Venetian Macao in 2011. She continued visiting the Macau property until 2024.
Hu entered into a credit arrangement with Venetian Macau in November 2023 that allowed her to access up to HK$15 million (US$1.9 million) for gambling. She also signed a promissory note and authorization documents connected with the credit facility.
After the amount remained unpaid, Venetian Macau pursued the claim in Hong Kong. A Hong Kong court issued a default judgment in March 2025 ordering Hu to pay HK$19.35 million, together with interest at 18% annually from October 29, 2024, until the debt was settled, plus legal costs.
The casino operator then registered the Hong Kong judgment in Singapore under the Reciprocal Enforcement of Foreign Judgments Act 1959. It also secured an order allowing the seizure and sale of property belonging to Hu in Singapore.
Hu challenged that registration. Judge Philip Jeyaretnam ultimately ruled that Singapore could not be used to enforce the gambling-related debt.
Gambling Debt Falls Under Singapore Public Policy
The court based its decision on Singapore’s longstanding restrictions concerning gambling and wagering debts.
Section 5(2) of the Civil Law Act 1909 provides that contracts made through gaming or wagering are null and void and prevents legal action to recover money won on a wager. Singapore subsequently created specific exceptions through the Casino Control Act 2006 for credit extended by its locally licensed casinos.
Those exceptions apply to Marina Bay Sands and Resorts World Sentosa. The court found that the legislation does not provide the same exemption for casinos operating outside Singapore.
Venetian Macau argued that the promissory note should be treated independently from the gambling arrangement. Jeyaretnam rejected that position after considering the purpose for which the document was issued.
According to Asia Gaming Brief, the judge determined that the promissory note was “consideration for – and inextricable from – the arrangement” that enabled Hu to gamble on credit at The Venetian Macao.
The court therefore concluded that the form of the documentation did not change the underlying nature of the debt. Enforcing the Hong Kong judgment through Singapore’s courts would conflict with the country’s public policy.
Hu had also challenged the Hong Kong proceedings on grounds involving notice, alleged fraud and the jurisdiction of the Hong Kong court. The Singapore High Court rejected those arguments. The successful challenge concerned the enforceability of the judgment in Singapore.
Jeyaretnam stressed the limited scope of the decision, noting that “Casinos can still attempt to enforce their causes of action elsewhere.”
The judgment therefore leaves the Hong Kong order intact. It also does not establish that Hu has no outstanding obligation under Hong Kong law.
Court Rejects Reliance on Earlier Casino Case
Venetian Macau relied on a 2004 Singapore case involving a gambling debt incurred at an Australian casino.
In Liao Eng Kiat v Burswood Nominees Ltd [2004] SGCA 45, Singapore’s Court of Appeal had permitted enforcement of a judgment concerning an AU$50,000 (US$35,000) debt incurred at Burswood casino, now known as Crown Perth.
Jeyaretnam distinguished that decision because it was made under the former Reciprocal Enforcement of Commonwealth Judgments Act. That legislation has since been repealed and replaced by the Reciprocal Enforcement of Foreign Judgments Act.
The judgment also considered Poh Soon Kiat v Desert Palace Inc [2010] 1 SLR 1129, which had questioned aspects of the reasoning in the earlier Burswood decision and indicated that the issue could be reconsidered if it arose again.
The court’s treatment of those precedents reinforced the distinction between enforcing foreign judgments generally and enforcing gambling-related claims through Singapore’s courts.