Punitive damages for breach of contract

In the recent decision of PH Hydraulics & Engineering Pte Ltd v Airtrust (Hong Kong) Ltd [2017] SCGA 26, the Singapore Court of Appeal considered whether punitive damages could be awarded for breach of contract. In doing so, the Court was tasked with choosing between Canadian jurisprudence, which permits punitive damages in contract cases, and English jurisprudence, which forbids them. The Court ultimately decided against making an award of punitive damages and followed the reasoning of earlier English courts. However, Leong JA, who wrote the leading judgment, refused to rule out the prospect of allowing an award of punitive damages in the future. In this respect, it seems that Singaporean courts are more amenable than their English counterparts towards punishment in the private law.