Singh v Singh [1971]

Key Points:

• Early Standard for Duress:

◦ In Singh v Singh, the court maintained that, for a marriage to be considered voidable due to duress, the threat needed to be severe, typically involving a threat to "life, limb, or liberty." This standard set a high threshold for what constituted duress.

• Narrow Interpretation:

◦ The case reflected a narrower interpretation of duress, focusing primarily on physical threats or extreme forms of coercion. Psychological or emotional pressures were not typically seen as sufficient to void a marriage.

Impact and Analysis:

• Limitations of Early Law: The Singh case highlighted the limitations of early legal interpretations of duress, which required a significant, tangible threat to invalidate a marriage. This approach often failed to account for more subtle, yet equally coercive, forms of pressure.

• Evolution in Legal Standards: Subsequent cases, such as Hirani v Hirani (1983), expanded the understanding of duress to include emotional and psychological pressures, moving away from the strict requirement of threats to "life, limb, or liberty" established in Singh.