I.

COSTS

Ref: LN01

What are costs

Who can claim costs
Type of costs
Different bases of costs
Entitlement to costs
When and how much can be claimed
Procedure for quantifying costs
Procedure for taxation
Penalties for excessive charging

A.

DEFINITION OF COSTS

1.

2.

B.

No exhaustive definition
O. 59, r. 1(1): costs include:
o Fees, charges, disbursements, expenses and remuneration

COSTS NOT THE SAME AS DAMAGES

Damages are the monetary compensation for the loss caused to a party by another partys
breach.
Costs are the expenses incurred in pursuing a case against another party. It is for work done.

RECEIVING PARTY = PARTY WHOM COSTS PAYABLE

The receiving party is the party to whom costs are payable.
The paying party is the party who is liable to pay costs.

TYPES OF COSTS (P&P AND S&C)

Party-and-party (P & P) costs
o Costs that are payable by one party in a litigation case to the other parties.
o Usually standard basis but indemnity basis can apply too.
Solicitor-and-client (S & C) costs
o Costs that are payable by a party to his own solicitor.
o Usually indemnity basis except for non-contentious business.

C.

BASIS FOR TAXATION

2 main basis of taxation:
o Standard
o Indemnity
o (uncommon) Compensatory costs (O 59 r 18A)

Claimable costs

Reasonable amount
viz. all costs
reasonably incurred

Indemnity**
O. 59, r. 27(3)
By agreement, legislation or
exceptional circumstances
(e.g., costs to own solicitor)
All costs EXCEPT those
unreasonably incurred or of
an unreasonable amount

Doubts resolved in
favour of *

Paying party

Receiving party

Relevant provision
Applies when

Standard
O. 59, r. 27(1), (2)
Standard basis

Compensatory
O. 59, r. 18A
Litigant in person

Costs to reasonably
compensate litigant for
time expended + all
expenses reasonably
incurred
NA

*Resolving in favour =/= invariably accepting at face value (Lin Jian Wei v Lim Eng Hock Peter)
o Resolution of doubts = a rigorous process
o Only in matters where the Court is still left in real doubt at the end of a searching
review process should doubts about reasonableness be resolved in favour of the
receiving party
o Reference to burden of proof?? Or onus of proof?

** Indemnity costs estimated at one-third more than standard costs but NOT A HARD AND FAST
RULE (Lin Jian Wei v Lim Eng Hock Peter at [83])
o Ordinarily, under the old regime, solicitor and client costs were about one third more
than party and party costs
o there now appears to be a general practice whereby costs assessed on an indemnity
basis are taken to be usually one third more than that assessed on a standard basis
o this is not a hard and fast rule which applies invariably each time costs are ordered to
be taxed on an indemnity basis.

1.

DEFAULT STANDARD BASIS (O. 59, R. 27(1), (2))

Reasonable amount viz. all costs reasonably incurred
Any doubts resolved in favour of paying party

(2) On a taxation of costs on the standard basis, there shall be allowed a reasonable amount in
respect of all costs reasonably incurred and any doubts which the Registrar may have as to whether
the costs were reasonably incurred or were reasonable in amount shall be resolved in favour of the
paying party; and in these Rules, the term the standard basis, in relation to the taxation of costs,
shall be construed accordingly.

Default basis of taxation, unless RoC says or Court feels otherwise (O. 59, r. 27(1))

Basis of taxation (O. 59, r. 27)

27.(1) Subject to the other provisions of these Rules, the amount of costs which any party shall be
entitled to recover is the amount allowed after taxation on the standard basis where

(a) an order is made that the costs of one party to proceedings be paid by another party to those
proceedings;
(b) an order is made for the payment of costs out of any fund; or
(c) no order for costs is required,
unless it appears to the Court to be appropriate to order costs to be taxed on the indemnity basis.

2.

BY AGREEMENT OR EXCEPTIONAL CIRCUMSTANCES INDEMNITY BASIS

(O. 59, R. 27(3))
All costs EXCEPT those UNREASONABLY INCURRED or of an UNREASONABLE AMOUNT
Any doubts resolved in favour of receiving party

(3) On a taxation on the indemnity basis, all costs shall be allowed except in so far as they are of an
unreasonable amount or have been unreasonably incurred and any doubts which the Registrar may
have as to whether the costs were reasonably incurred or were reasonable in amount shall be
resolved in favour of the receiving party; and in these Rules, the term the indemnity basis, in
relation to the taxation of costs, shall be construed accordingly.

3.

Ordered when:
o Agreed to between parties that costs would be recoverable on an indemnity basis (UOB
v Sin Leong Ironbed and Furniture Manufacturing Co (Pte) Ltd)
o Exceptional circumstances or in a special case
Lee Kuan Yew v Vinocur
Teo Siew Peng v Neo Hock Peng
Where the parties acted unreasonably: Tjiong Very Sumito v Antig
Investments

COSTS AWARDED TO A LAY PERSON COMPENSATORY BASIS (O. 59, R.

18A)
Applies to litigant in person (lay person)
Reasonably compensate for time expended and reasonable expenses incurred

Litigants in person Compensatory costs (O. 59, r. 18A)

18A. On a taxation of the costs of a litigant in person, there may be allowed such costs as would
reasonably compensate the litigant for the time expended by him, together with all expenses
reasonably incurred.

D.

ENTITLEMENT TO COSTS

An entitlement to costs will usually arise under:

Legislation (primary or secondary)

o E.g., O 59 r 10 - discontinuation of action
o O 59 r 31 and App 2 to O 59 - costs as per scale
o
O 59 r 3(3): amendments to writ or pleadings without leave (party amending)
o O 59 r 3(4): application to extend time (party extending)
Contract
o E.g., An entitlement to costs under contract usually arises between solicitors and clients,
by application of s 120(3) of the Legal Profession Act.

In any case where a solicitor and his client consent to taxation of a solicitors
bill, the Registrar may proceed to tax the bill notwithstanding that there is no
order therefor.
o Contract can however form the basis of costs between 2 parties to litigation.
A judgment or order of the court
o Entitlements to costs are most commonly founded on orders of court.
o The orders for costs are usually made under the general power in O 59 r 2(2).
o Orders in relation to S & C costs are also made under s 120(1) of the Legal Profession
Act.
An order for the taxation of a bill of costs delivered by any solicitor may be
obtained on an application made by originating summons or, where there is a
pending action, by summons by the party chargeable therewith, or by any
person liable to pay the bill either to the party chargeable or to the solicitor, at
any time within 12 months from the delivery of the bill, or, by the solicitor,
after the expiry of one calendar month and within 12 months from the delivery
of the bill.
Matters to be decided by the court before making an order for costs:
o Who should pay the costs?
o What costs should be awarded?
o What type of costs should be awarded, i.e., fixed costs, taxed costs or costs as per scale?
o If taxed costs, what basis of taxation?
Power of the court to order costs (O. 59, r. 2(2); O. 59, r. 4(1))
o O. 59, r. 2(2): Subject to the express provisions of any written law and of these Rules,
the costs of and incidental to proceedings in the Supreme Court or the State Courts,
including the administration of estates and trusts, shall be in the discretion of the Court,
and the Court shall have full power to determine by whom and to what extent the costs
are to be paid.
o O. 59, r. 4(1): Costs may be dealt with by the Court at any stage of the proceedings or
after the conclusion of the proceedings; and any costs ordered shall be paid forthwith
notwithstanding that the proceedings have not been concluded, unless the Court
otherwise orders.
Costs to follow event (O. 59, r. 3(2))
o O. 59, r. 3(2): The court shall order the costs to follow the event, except when it
appears to the Court that in the circumstances of the case some other order should be
made as to the whole or any part of the costs.
o Tullio v Maoro; Re Elgindata (No 2); Wing Joo Loong Ginseng Hong (Singapore) Co Pte
Ltd v Qinghai Xinyuan Foreign Trade Co Ltd: general rule is that costs are to follow the
event UNLESS there are special reasons or circumstances, e.g.:
Plaintiff with nominal damages treated as loser: Anglo-Cyprian Trade Agencies
Ltd v Paphos Wine Industries Ltd; Mahtani v Kiaw Aik Hang Land Pte Ltd
Party successful in suit but had acted in bad faith (successfully resisting an
anti-injunction suit, but had applied to the Swedish court for a divorce decree
even though he knew of the anti-suit injunction application: VH v HI)
Cf. that plaintiff should be awarded full damages so long as he substantially
succeeded in the action (two-thirds of suit: Parno v SC Marine Pte Ltd)
Factors to consider in awarding costs (O. 59, r. 7(2))
o O. 59, r. 7(2): The Court shall have regard of the following:
(a) the omission to do any thing the doing of which would have been calculated
to save costs;

(b) the doing of any thing calculated to occasion, or in a manner or at a time

calculated to occasion unnecessary costs; and
(c) any unnecessary delay in the proceedings.
Costs to follow event, but paid by someone else (Chua Teck Chew Robert v Goh Eng Wah)
o Where a Pf is successful against one Df but is successful against another Df, a Bullock
order or a Sanderson order can be made (Denis Matthew Harte v. Dr Tan Hun Hoe and
Gleneagles Hospital Ltd; DBS Vickers Securities (Singapore) Pte Ltd v Chin Pang Joo;
Chua Teck Chew Robert v Goh Eng Wah)
o Principal consideration in a Sanderson order is whether it would be fair and reasonable
for the unsuccessful Df to bear the costs of the successful Df (Chua Teck Chew Robert v
Goh Eng Wah)
E.g., that the unsuccessful Df had tried to shift blame to the other two Dfs, and
if it was therefore reasonable for the Pf to have also sued the other co-Dfs
(Chua Teck Chew Robert v Goh Eng Wah)

Bullock order

Sanderson order

E.
1.

ORDERS FOR COSTS

COMMON ORDERS FOR COSTS

Common orders
Costs to party

Remarks
Entitles party to tax costs forthwith: O. 59, r. 4
Follows general rule costs to follow event: O. 59, r. 3(2)

Costs reserved

Where court does not wish to make final determination as to costs, e.g.,
unclear as to event or if costs really reasonable.
If no subsequent order, then = costs in the cause.

Costs in any
event

Same as order for costs, but only tax after conclusion of cause or matter
Made when desirable not to have taxation forthwith

Costs here and

below

Costs of proceedings before instant tribunal and tribunal/court below

Often made for successful, fully meritorious appeals

Costs in the
cause

Usual order when event which resulted in costs being incurred

Normal incident of litigation with no clear fault of either party, e.g., O. 14
Interlocutory application where no decision on the merits by the courts, then
costs in the cause: Chiarapurk Jack v Har Par Brothers International Ltd

Pf/Dfs costs in
the cause

If beneficiary of order gets general costs of action, then he gets costs of e.g.,
application; if not, no party gets costs

Costs thrown
away

Usually made when costs wasted by action of one party: costs which must be
incurred again
Desirable to have order further defined to avoid doubt
Danger of not defining: Choo Ah Kiat v Ang Kim Hock

Each party bears its own costs

No order as to
costs

2.

TYPES OF ORDERS OF COSTS

Two types of orders for costs:

Type of order
Taxed costs
Lump sum or
fixed costs

Relevant provision
O. 59, r. 9(1)
Legislation +
O. 59, r. 9(4)

Remarks
Default position
Where prescribed by legislation, e.g., O. 59 r. 31(2) &
App. 2 to O. 59, for e.g.,
o Final judgment in default of appearance
o Final judgment in default of defence
o Final judgment under Order 14
If the court thinks fit: O. 59, r. 9(4)
o would assist in avoiding the expense, delay and
aggravation involved in a protracted litigation
arising out of taxation: Leary v Leary
o taxing registrar would not be in a better position
to assess the costs: Wong Yit Shing v Sim Teow
Gok

Costs can be fixed on a standard or indemnity basis

F.

1.

TAXATION PROCESS
Entitlement to costs =/= entitlement to have costs taxed
Must begin process of taxation by filing a copy of the bill of costs at the Registry: O. 59, r. 20
o Done by party entitled to costs
o Taxation merely a quantification process

FORM OF BILL OF COST S (O. 59, R. 24(1))

Costs of three separate sections

Section
Section 1

Remarks
All the work done in the cause or matter for which the
costs are being taxed
o EXCEPT costs incurred in the taxation of costs

Claimed as
One global sum

Section 2

The work done for and in the taxation of the costs

One global sum

Section 3

All disbursements incurred in the cause or matter.

The amount claimed for each and every individual
expense must be set out.

2.

CONTENT OF BILL OF COSTS

Sections
Applicant
Nature of Bill
Basis of taxation
Basis for taxation

3.

Remarks
State the party for whom the bill is filed
State P&P or S&C
Standard or indemnity
Judgment/Order of Court dated [DD/MM/YY] ordering taxation
Stating receiving and paying party

FORMAT OF BILL OF CO STS (SUP. CT. PRACTICE DIRECTION NO. 7 OF 2005)

Three formats wef 15 July 2005
o Bill of Costs for Contentious Business Trials (including in contemplation of)
o Bill of Costs for Contentious Business Other than Trials (isolated appeals/applications
only)
o Bill of Costs for Non-Contentious Business

A)

Section
Section 1

BILL OF COSTS FOR CONTENTIOUS BUSINESS WORK DONE IN

CONTEMPLATION OF TRIALS (F 16A)
Remarks
All the work done other than for taxation
o The claim
o Pleadings
o Interlocutory attendances
o Discovery
o Trial
o Complexity of case

o
o
o
o

Urgency and importance to client

Time and labour expended
Counsel and solicitors involved
Costs claimed

Section 2

Work done for taxation

o Describe the work done for the preparation of the Bill of Costs and the
taxation of the bill

Section 3

Disbursements
o Set out the amount of each disbursement incurred and to be claimed

4.

PROCEDURE AFTER LODGEMENT OF THE BILL OF COSTS

A)

Fixed for hearing and registrar gives receiving party not less than 14 days notice of the date and
time appointed for the taxation: O 59 r 21.
Copy of the bill of costs must be sent to every other party entitled to be heard at the taxation
within 2 days after the receiving party obtains notice of the date and time of the taxation: O 59 r
22(1).
Paying parties may object to the amounts claimed in the bill:
Supreme Court
o Any objections in principle or as to the quantum of the items claimed in a bill must be
indicated by the filing and service of a Notice of Dispute in Form 21 of Appendix B at
least 7 days before the date fixed by the Registrar for the taxation of the bill [para 84,
PD].

B)

TAXATION HEARING

Parties who wish to be heard on the bill attend before the taxing registrar on the date fixed for
the taxation.
If the taxation is expected to be lengthy and complex, parties may consider applying by letter for
a special date for the hearing. If not, then the bill of costs will be taxed on a normal date.

C)

PRE-HEARING

POST-HEARING

If parties are satisfied with the costs allowed on the taxation:

o Registrars certificate prepared setting out costs allowed.
o Court fees paid on the registrars certificate.

If the bill of costs is withdrawn, item no. 88 of Appendix B requires the Registry to charge a
withdrawal fee. This fee may be as high as the full fee payable in respect of the taxed costs and is
subject to a minimum of $50 (MC), $100 (DC) or $200 (HC).

D)

G.

Registrars certificate signed and sealed and released to the receiving party.

REVIEW IN THE HIGH COURT FROM STATE COURTS/RIGHT TO APPEAL

If any party is dissatisfied with decision of the registrar, he may seek a review before a judge (O
59, r 34):
o any party may apply to a Judge to review the taxation - O59, r 34(1)
o within 14 days after that decision, or such longer time as the Registrar or the Court at
any time may allow- O59, r 34(2)
o Application for a review before a judge is made by way of summons: O 59 r 34(3).
At the hearing of the review before the judge, the court hears the taxation de novo and is not
fettered by the discretion exercised by the Registrar: Tan Boon Hai v Lee Ah Fong & Anor; O. 59,
r. 35.
If the taxation took place in the High Court, appeal lies to the Court of Appeal subject to leave:
SCJA, s. 34(2)(b).
If the taxation took place in the Subordinate Courts, then a party may appeal to the High Court.
Right to appeal is unrestricted if the amount in dispute is more than $50,000: SCJA, s. 21(1)

QUANTIFICATION OF COSTS

Defining provisions
Definition

Costs provisions for

quantification

Contentious business
s. 2(1), LPA
business done in or for the purposes of
proceedings begun before a court of
justice or before an arbitrator
[includes work done prior to
proceedings but in contemplation of
it: Re Simpkin Marshall Ltd]
O 59 r 31(1):
Provisions in Appendix 1 to O 59
for quantifying costs only apply to
costs in respect of contentious
business.

Non-contentious business
By exclusion from s. 2(1), LPA
All business which is non-contentious

s. 108, LPA
Quantification rules set out in
the Legal Profession (Solicitors
Remuneration) Order

Three main factors

o Basis of taxation
o Circumstances relevant to the cause or matter underlying the bill of costs.

have regard to the principle of proportionality* and all the relevant

circumstances and, in particular, to the following matters: Lin Jian Wei v Lim
Eng Hock Peter; O. 59, App. 1, para. 1(2), including the 6 sets of circumstances:
Complexity/novelty of matter

Skill, specialized knowledge etc. required, time and labour expended

Number and importance of documents perused/prepared
Place and circumstances in which the business is involved is transacted
Urgency and importance of the cause or matter to client
Value or amount of money/property in question
No single consideration ordinarily to take precedence (Lin Jian Wei v Lim Eng
Hock Peter)
Reasonableness:
Correct viewpoint to be adopted by a taxing officer is that of a sensible solicitor
sitting in his chair and considering what in the light of his then knowledge is
reasonable in the interests of his lay client: Francis v Francis and Dickerson;
Bush v Bower Cotton & Bower (a firm)
Disproportionate to value of claim =/= reasonably incurred: Lin Jian
Wei v Lim Eng Hock Peter
P&P costs SHOULD NOT exceed S&C costs: Gundry v Sainsbury

Amounts of costs allowed in respect of similar causes or matters.

Requires careful judgement by reference to precedent and guidelines (Lin Jian
Wei v Lim Eng Hock)
Ascertain the amount of costs allowed for similar cases: see bill of costs
summaries or LawNet Taxation Information System
(http://www.lawnet.com.sg/liti.shtml).
Consider all relevant circumstances in deciding what a reasonable amount of
costs is.

Court should first assess the (Lin Jian Wei v Lim Eng Hock):
o relative complexity of the matter,
o work supposedly done against what was reasonably required,
o reasonableness and proportionality of the amounts claimed on an item by item basis
o and thereafter, assess the proportionality of the resulting aggregate costs

If proceedings commenced in HC, when it could have been commenced in the State Courts, Pf
may only receive costs he would have received if he commenced it in State Courts: State Courts
Act, s. 39; O. 59, r. 27(5)

H.

QUANTIFICATION OF SOLICITOR AND CLIENT COSTS

Right to have solicitor and client costs taxed governed by s 120 Legal Profession Act.
Normally obtain taxation of S & C costs in 2 ways:
o Order under originating summons: s 120(1).
o By consent of parties: s 120(3).

Solicitor and client bills of costs should be drawn up in accordance with O 59 and the practice
directions, and the procedure set out in O 59 will govern the taxation: Legal Profession Act, s 126
O 59 r 28 and Appendix 1 to O 59 apply to taxations of solicitor-and-client bills of costs in relation
to contentious business. Bills will be taxed on the indemnity basis and presumptions set out in O
59 r 28(2) will apply.

1.

2.

3.

COSTS PAYABLE TO A SOLICITOR BY HIS OWN CLIENT

It is a question of fact to be evaluated on a case-by-case basis. O 59 r 28 governs the situation.
The following are looked into:
o (a) whether the costs was incurred with the express or implied approval of the client;
o (b) whether the amount was reasonable as approved to be incurred by client; and
o (c) to have been unreasonably incurred if, in the circumstances of the case, they are of
an unusual nature unless the solicitor satisfies the Registrar that prior to their being
incurred he informed his client that they might not be allowed on a taxation of costs
inter partes.

TAXATION OF S&C BILL S OF COST

O 59 r 28(5) allows solicitor to claim a larger sum in the bill of costs submitted for taxation than
the amount claimed in the bill originally rendered to the client and also permits the court to allow
on taxation more costs than were claimed in the original bill.
Client may no longer argue that any consent to taxation, or order for taxation was only in respect
of the bill originally rendered to the client: O 59 r 28(4).
There is a difference between taxations of party-and-party costs on the indemnity basis and the
taxation of solicitor-and-client costs on the same
o S&C is a private matter: Lin Jian Wei approval >>> than principle of proportionality
o Cf. P&P where principle of proportionality will apply with greater force due to policy
reasons: Lin JIan Wei
The O 59 r 28(2) presumptions only apply to taxations of solicitor and client bills.

COSTS FOR MORE THAN TWO SOLICITORS

O 59 r 19. On a party-and-party taxation, a party is generally entitled to recover the costs of
having up to two solicitors acting for him, subject to
o reasonableness under r 3) and
o if the court so certifies under r 1
Time to do so. The requesting party must apply to the Court to so certify at the hearing or
within 1 month from the date of judgment or order.
Allowed only if the services of more than one counsel are reasonably necessary for the adequate
presentation of the case (Stanley v Phillips; Singapore Airlines Ltd v Fujitsu Microelectronics
(Malaysia) Sdn Bhd; Colliers International (Singapore) Pte Ltd v Senkee Logistics Pte Ltd)
o Costs allowed for two counsel indication that subject matter was not complex
BC 247 also claimed cost for six solicitors and counsel with considerable
overlapping of work (Lin Jian Wei v Lim Eng Hock Peter)
One-sixth rule *s 128(1), Legal Profession Act+:
o Applicable to solicitor-and-client bills of costs taxed under an order of court
o If one-sixth or more of the bill is taxed off, then the solicitor must pay costs of the
taxation as well as the costs of obtaining the order for taxation.
o If less than one-sixth of the bill is taxed off, then the party chargeable must pay the
costs of the taxation as well as the costs of obtaining the order for taxation.
NB: r. 19 DOES NOT AFFECT costs for pupils when considering P-P costs (Lin Jian Wei)

4.

COST PENALTIES AGAINST LAWYERS

PERSONAL LIABILITY
INCOMPETENCE; IMPROPERLY OR UNREASONABLY INCURRED VIZ. PROCEEDINGS (O 59 r 8(1))
o Costs have been incurred unreasonably or improperly
o Costs have been wasted by failure to conduct proceedings with reasonable
competence and expedition.
o CONSEQUENCES:
(a) disallowing the costs as between the solicitor and his client; and
(b) directing the solicitor to repay to his client costs which the client has been
ordered to pay to other parties to the proceedings; or
(c) directing the solicitor personally to indemnify such other parties against
costs payable by them.

NEGLECT OR DELAY; UNNECESSARY EXPENSE VIZ. TAXATION (O 59 r 8(6))

o Where the solicitor representing any party to the taxation is guilty of neglect or delay,
or puts any other party to unnecessary expense in relation to the taxation. Costs have
been wasted by failure to conduct proceedings with reasonable competence and
expedition.
o Where a solicitor fails to leave his bill of costs for taxation within the time fixed by an
order of court.
o Where a solicitor impedes or delays the taxation.

Taxed-off = amount struck off

Where one-half or more of the total amount of the bill (i.e., section 1 + section 2 + section 3) is
taxed off: O 59 r 8(7), court may (IN ITS DISCRETION) order:
o That the solicitor who presented the bill:
Stamp the bill with the fees payable under item no. 86 of Appendix B as if the
bill of costs had been allowed at the full amount claimed;
Be entitled to claim from the paying party (for a party-and-party bill) or his
client (for a solicitor-and-client bill) only the fees payable under item no. 86 of
Appendix B in respect of the actual costs allowed;
Pay personally the difference in taxing fees; and
Pay personally the fee for the Registrars Certificate.
o NB: Applies to all types of bills (P&P and S&C, indemnity or standard basis)

Differences between the rule in s 128(1) of the Legal Profession Act (commonly known as the
one-sixth rule) and O 59 r 8(7).
o The one-sixth rule only applies to a particular type of bill of costs, namely, a bill in
which solicitor-and-client costs are claimed, and where an order for the taxation of the
bill of costs was obtained on an originating summons. The one-half rule applies to all
bills of costs.
o The one-sixth rule is mandatory in its operation, and the court does not have a
discretion as to whether to apply or dis-apply the rule. The one-half rule is purely
discretionary.

The one-sixth rule affects the incidence of the liability to pay the costs of the taxation and the
costs of obtaining the order for taxation. The first limb of the one-half rule affects the right to
recover the costs of the taxation only.

I.

Under the one-sixth rule, if one-sixth or more of the costs claimed in a bill is taxed off, the
solicitor will be actually liable to pay the client the costs the client incurred for the taxation and
obtaining the order for taxation. Under the first limb of one-half rule, the solicitor can only be
disallowed his own costs of the taxation; he cannot be ordered to pay costs to another person.

ENFORCING TAXED COSTS

General rule:
o A Registrar's Certificate (RC) is not equivalent to a judgment or order for the payment of
money. To enforce, must first obtain judgment in a separate action on the RC.
Specifically:
o O 59 r 33 - may execute on the RC where the order granting taxation on an originating
summons against the client containing a submission to pay.
o See Commercial Bank of Kuwait SAK v Nair (Chase Manhattan Bank NA, garnishees
[1994] 1 SLR 197