Durairaj Santiran v Singapore Airlines: Negligence & Employer's Duty of Care
In Durairaj Santiran v Singapore Airlines Ltd, the General Division of the High Court of Singapore heard a negligence claim by Durairaj Santiran, a flight steward, against his employer, Singapore Airlines, for injuries sustained from a fall on 6 September 2019. Santiran alleged a breach of duty of care due to a slippery area on the aircraft floor. Justice Vinodh Coomaraswamy dismissed the claim, finding no evidence of a slippery area and no breach of duty of care by Singapore Airlines. The court did not analyze causation, defenses, or quantum.
1. Case Overview
1.1 Court
General Division of the High Court of the Republic of Singapore1.2 Outcome
Claim Dismissed
1.3 Case Type
Civil
1.4 Judgment Type
Judgment
1.5 Jurisdiction
Singapore
1.6 Description
Flight steward Durairaj Santiran sues Singapore Airlines for negligence after a fall. The court dismissed the claim, finding no breach of duty of care.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Durairaj Santiran | Claimant | Individual | Claim Dismissed | Lost | |
| Singapore Airlines Ltd | Defendant | Corporation | Judgment for Defendant | Won |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Vinodh Coomaraswamy | Judge | Yes |
4. Counsels
4. Facts
- The claimant, a flight steward, fell on the floor of the defendant's aircraft on 6 September 2019.
- The claimant alleged that he slipped on a patch of grease on the floor of the economy class galley.
- The defendant denied the existence of a slippery area and any breach of duty of care.
- The claimant had six other workplace injuries between April 2017 and April 2019.
- The defendant allowed the claimant’s employment contract to expire without offering him a fresh contract.
- The claimant now works as a customer care analyst at Ricoh (Malaysia) Sdn Bhd.
5. Formal Citations
- Durairaj Santiran v Singapore Airlines Ltd, Originating Claim No 136 of 2022, [2024] SGHC 249
6. Timeline
| Date | Event |
|---|---|
| Claimant employed by defendant | |
| Claimant injured back | |
| Claimant suffered bruises on left forearm | |
| Claimant hit left thumb on meal cart | |
| Claimant slipped and fell from staircase | |
| Claimant had surgery to fuse C5/C6 vertebrae | |
| Claimant broke left fingernail | |
| Claimant bruised tip of finger | |
| Claimant fell on aircraft | |
| Claimant's employment contract expired | |
| Claimant started work at Ricoh (Malaysia) Sdn Bhd | |
| Trial began | |
| Judgment reserved | |
| Judgment issued |
7. Legal Issues
- Breach of Duty of Care
- Outcome: The court found that the defendant did not breach its duty of care to the claimant.
- Category: Substantive
- Sub-Issues:
- Failure to provide a safe place of work
- Failure to provide a safe system of work
- Negligence
- Outcome: The court dismissed the negligence claim.
- Category: Substantive
8. Remedies Sought
- Monetary Damages
9. Cause of Actions
- Negligence
10. Practice Areas
- Personal Injury
- Workplace Injury
11. Industries
- Aviation
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Sandz Solutions (Singapore) Pte Ltd and others v Strategic Worldwide Assets Ltd and others | High Court | Yes | [2014] 3 SLR 562 | Singapore | Cited regarding limitations of assessing demeanour in the witness box. |
| How Weng Fan and others v Sengkang Town Council and other appeals | Court of Appeal | Yes | [2023] 2 SLR 234 | Singapore | Cited for the purposes of pleadings. |
| V Nithia (co-administratrix of the estate of Ponnusamy Sivapakiam, deceased) v Buthmanaban s/o Vaithalingam and another | High Court | Yes | [2015] 5 SLR 1422 | Singapore | Cited for the purposes of pleadings. |
| Spandeck Engineering (S) Pte Ltd v Defence Science & Technology Agency | Court of Appeal | Yes | [2007] 4 SLR(R) 100 | Singapore | Cited for the elements of a negligence claim and the test for duty of care. |
| BNJ (suing by her lawful father and litigation representative, B) v SMRT Trains Ltd and another | High Court | Yes | [2014] 2 SLR 7 | Singapore | Cited for the standard of care and res ipsa loquitur. |
| Chandran a/l Subbiah v Dockers Marine Pte Ltd | Court of Appeal | Yes | [2010] 1 SLR 786 | Singapore | Cited for the standard of care an employer must take for its employees’ personal safety. |
| Stokes v Guest, Keen and Nettlefold (Bolts and Nuts) Ltd | English Court of Appeal | Yes | [1968] 1 WLR 1776 | England and Wales | Cited for the standard of care an employer must take for its employees’ personal safety. |
| Parno v SC Marine Pte Ltd | High Court | Yes | [1999] 3 SLR(R) 377 | Singapore | Cited for the duty to provide employees a proper system of work. |
| Lu Bang Song v Teambuild Construction Pte Ltd and another and another appeal | High Court | Yes | [2009] SGHC 49 | Singapore | Cited regarding imposing an overly onerous duty on an employer. |
| Awang bin Dollah v Shun Shing Construction & Engineering Co Ltd and other appeals | Court of Appeal | Yes | [1997] 2 SLR(R) 746 | Singapore | Cited regarding res ipsa loquitur. |
| Chandler v Cape plc | English Court of Appeal | Yes | [2012] 1 WLR 3111 | England and Wales | Cited regarding duty of care. |
| Hao Wei (S) Pte Ltd v Rasan Selvan | High Court | Yes | [2009] 1 SLR(R) 142 | Singapore | Cited regarding duty of care. |
| General Cleaning Contractors Ld v Christmas | House of Lords | Yes | [1953] AC 180 | United Kingdom | Cited regarding duty of care. |
| Management Corporation Strata Title Plan No 2668 v Rott George Hugo | High Court | Yes | [2013] 3 SLR 787 | Singapore | Cited regarding duty of care. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Work Injury Compensation Act 2019 | Singapore |
| Evidence Act 1893 | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Duty of care
- Negligence
- Slippery floor
- Workplace injury
- Flight steward
- Safe system of work
- Safe place of work
- Grease patch
- Cabin crew
- CCRP
- SSQH
15.2 Keywords
- Negligence
- Duty of care
- Workplace injury
- Singapore Airlines
- Flight steward
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Negligence | 95 |
| Torts | 75 |
| Employment Law | 50 |
| Causation | 30 |
| Contributory negligence | 30 |
| Evidence Law | 20 |
| Measure of Damages | 20 |
| Vicarious liability | 10 |
16. Subjects
- Tort Law
- Employment Law
- Negligence
- Personal Injury