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 judgement rules it enforceable.
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 judgement 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.
Venetian then sought to pursue assets held by Hu in Singapore and registered the Hong Kong judgement under Singapore’s Reciprocal Enforcement of Foreign Judgments Act 1959 (REFJA), 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.
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 for 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 a AU$50,000 (US$35,000) debt accrued by a player at the Burswood casino (now Crown Perth) in Australia.
In doing so, Judge Jeyaretnam pointed out that the Burswood ruling was made under the old Reciprocal Enforcement of Commonwealth Judgments Act (RECJA) 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.
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.
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.
Singapore is, ironically, home to the iconic Marina Bay Sands integrated resort, whose parent company Las Vegas Sands (LVS) is also the controlling shareholder in Sands China and in turn Venetian Macau Ltd.
LVS only last week increased its stake in Sands China to 75.01%.
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