Introduction
In a judgment delivered by the Singapore High Court in Crystal Beauty Pte Ltd v Xu Jasmine and another [2025] SGHC 86, the court examined a claim by a commercial property purchaser against its appointed property agent. At the heart of the dispute was a discrepancy between the stated floor area of a property and the actual usable interior space, leading to claims of misrepresentation and professional negligence.
This case serves as a timely reminder to both property buyers and real estate professionals about the limits of what property agents are responsible for, the legal requirements for a successful misrepresentation claim, and why independent checks are essential when entering into any property transaction, especially for commercial purposes.
Background
Crystal Beauty Pte Ltd, a beauty salon operator, had been running its business out of #01-68, D’Leedon, Singapore. Looking to expand, the company considered purchasing a unit directly opposite, #01-62 at D’Leedon (the “Intended New Premises”). The property was advertised and listed on public platforms as having a floor area of 818 square feet. These representations were supported by official documents, including records from the Singapore Land Authority.
The deal proceeded and the purchase was completed. However, after the tenant vacated and the owner took possession, an interior designer hired to renovate the space discovered that the actual usable floor space was only about 619 square feet. This difference arose because the layout of the unit included inward-sloping walls that inflated the ceiling area relative to the usable floor. Feeling misled, the buyer brought a legal claim against the agent, seeking damages for alleged misrepresentation and failure to exercise proper care.
Legal Issue
The court’s decision turned on three key legal questions. First, the court asked whether the agent had told the buyer that the usable floor space was 818 square feet. A claim for misrepresentation requires that a clear factual statement be made, that it is untrue, and that the buyer acted in reliance on it. In this case, the court found that no such statement had been made. The agent had referred only to the total floor area as listed in property portals and title records, which followed common industry practice. There was no suggestion that the figure referred to the usable floor space. Furthermore, the buyer’s version of events was vague and inconsistent, weakening the claim.
Second, the court considered whether the buyer had relied on any such statement in making the decision to purchase the property. Reliance means that the buyer must have based their decision on what was said by the other party, rather than on their own assumptions or external factors. The court noted that the buyer had considered purchasing the same unit in 2018 and was already familiar with its layout. There was no evidence that anything newly said in 2020 played a material role in the decision to proceed with the purchase.
Third, the court examined whether the property agent had failed in their duty to take reasonable care. In Singapore, property agents must act honestly and competently, following the rules set out under law and by the regulatory authorities. However, the law does not impose a duty to detect unusual architectural issues unless there is some warning or reason to do so. In this case, the agent conducted routine checks using recognised property platforms and official government records. The layout quirk—which resulted in a smaller usable area—was so rare that even a professional expert engaged for the trial had never encountered it. There was nothing that would have alerted the agent to the need for more extensive investigation, and the court held that it would be unreasonable to expect the agent to obtain construction drawings or engage surveyors in an ordinary transaction like this one.
In light of all this, the court concluded that the agent had acted reasonably and professionally. There was no false statement and no failure in duty. As a result, the buyer’s claim was dismissed.
This decision clarifies the legal expectations placed on property agents and the responsibilities that buyers must shoulder. Agents are required to act honestly and to check basic facts, but they are not expected to guarantee every detail of a property’s layout or suitability unless specific concerns are raised. When it comes to unique features or non-standard configurations, buyers have a responsibility to conduct their own investigations.
The case also illustrates the difference between what is recorded in legal documents and what is physically usable. Strata area, which is the standard measure stated in title deeds and advertisements, may include walls or areas that are not practically usable. If a buyer requires a specific internal configuration—such as a certain number of rooms or working areas—they should verify the layout through measurements, floor plans, or expert consultation before completing the purchase.
It is also clear from this decision that courts will not accept generalised or ambiguous allegations. Legal claims must be based on specific, well-supported facts. Shifting positions or vague recollections will not satisfy the burden of proof required in a misrepresentation case.
Conclusion
The decision in this case provides a clear view of how courts assess disputes over property misrepresentation and agent responsibility. While agents do owe a duty to act carefully and in good faith, they are not liable for every unexpected outcome. Buyers must play their part in verifying that the property they intend to purchase meets their needs.
For businesses looking to purchase property for operational use, this case serves as a reminder that due diligence must go beyond surface representations. It is not enough to rely on listings or standard documents. Where space planning is important, the actual usability of the space should be professionally evaluated in advance.
