A Relative Died Overseas With Assets in Singapore: Resealing a Foreign Grant or Applying Afresh

By Johnathan Lee, Advocate and Solicitor (Singapore). Updated 28 September 2026.

If a relative died overseas leaving a bank account, shares or property in Singapore, the grant of probate or letters of administration issued abroad does not, by itself, operate as a Singapore grant. Under section 47 of the Probate and Administration Act 1934, a foreign grant can be resealed by the Family Justice Courts, after which it has the same effect as a Singapore grant. Resealing is available for grants from a court of probate in any part of the Commonwealth, and from any other country or territory the Minister has declared by Gazette notification (for grants made on or after the date the Minister specifies). If the grant does not qualify, or the deceased was not domiciled where it was issued and it is not a grant the Singapore court would have made, the family will generally need a fresh Singapore grant, following the procedure in Part 24 of the Family Justice Courts Practice Directions 2024.

Does a foreign grant work in Singapore on its own?

A grant of probate (where there is a will) or letters of administration (usually where there is no will) is a court order appointing the person who may collect and distribute the estate. It is made by the court of one country. The Act provides the route by which a foreign grant gains effect here: under section 47(2), once sealed by the Family Justice Courts, it “shall be of the like force and effect, and have the same operation in Singapore, as if granted by the General Division of the High Court”.

A Singapore bank or share registry may therefore ask for a Singapore or resealed grant before dealing with the assets. Before starting, check whether a grant is needed at all: the Singapore Courts website notes that a grant may not be required for some assets, or for estates not exceeding $50,000 that meet certain criteria.

What is resealing, and what does section 47 say?

Resealing means the Family Justice Courts place their seal on a grant made by a foreign court, so that the foreign executor or administrator can act in Singapore without starting again. Section 47(1) provides that, subject to subsections (3) and (4) (on domicile), where:

“(a) a court of probate in any part of the Commonwealth has, either before, on or after 25 February 1999, granted probate or letters of administration in respect of the estate of a deceased person; or (b) a court of probate in a country or territory, being a country or territory declared by the Minister under subsection (5) as a country or territory to which this subsection applies, has, on or after a date specified by the Minister in respect of that country or territory (referred to in this section as the relevant date), granted probate or letters of administration in respect of the estate of a deceased person, the probate or letters of administration so granted, or a certified copy thereof, sealed with the seal of the court granting the same, may, on being produced to and a copy thereof deposited in the General Division of the High Court, be sealed with the seal of the Family Justice Courts.”

Section 46 defines “court of probate” as any court or authority, by whatever name, having jurisdiction in matters of probate, and treats as probate or letters of administration any instrument that has, in its own country or territory, the same effect that Singapore law gives to probate or letters of administration (including confirmation in Scotland). The foreign document need not share the Singapore name. In In the matter of an application by WKQ and another matter [2023] SGHCF 12 at [21], the High Court described section 47 as empowering the Singapore court “to reseal letters of administration granted in certain foreign jurisdictions including Vanuatu”, and granted the application to reseal the Vanuatu grant (at [59]).

Which countries’ grants can be resealed in Singapore?

The Act has no schedule of countries. The list is set in two ways:

• Commonwealth. Section 47(1)(a) applies to grants from a court of probate “in any part of the Commonwealth”, whether made before, on or after 25 February 1999. The Act does not list the countries, so check that the issuing country qualifies.
• Declared countries or territories. Under section 47(5), the Minister may declare a non-Commonwealth country or territory by Gazette notification and specify the date from which its grants qualify. The Hong Kong SAR notification sets 1 July 1997 as that date.

In September 2026, the Hong Kong notification was the only declaration under section 47(5) shown among the subsidiary legislation listed under the Act on Singapore Statutes Online. A grant from a country or territory that is neither part of the Commonwealth nor declared falls outside section 47(1). Check the current position before filing, as notifications can change.

Situation	Usual route
Commonwealth grant, deceased domiciled in that country	Resealing
Hong Kong SAR grant made on or after 1 July 1997, deceased domiciled there	Resealing
Grant from a country neither in the Commonwealth nor declared	Fresh Singapore grant
Qualifying grant, but deceased domiciled elsewhere	Resealing only if the High Court would have made that grant; otherwise a fresh grant
No grant taken out abroad	Fresh Singapore grant

Why does the deceased’s domicile matter?

Domicile is, broadly, the country the law treats as a person’s permanent home. It is not necessarily the same as nationality or the place of death.

It can decide whether resealing is possible. Under section 47(3), the court may require evidence of domicile before sealing. Section 47(4) provides: “If it appears that the deceased was not, at the time of his death, domiciled within the jurisdiction of the court from which the grant was issued, the seal shall not be affixed unless the grant is such as the General Division of the High Court would have made.” The court set out this test in WKQ at [22].

It also affects who inherits where there is no will. Under section 4 of the Intestate Succession Act 1967, movable property (such as bank balances and shares) is distributed under “the law of the country in which he was domiciled at the time of his death”, while immovable property (land and flats) is distributed under that Act “wherever he may have been domiciled”. The Act does not apply to the estates of Muslims. My guide to intestate succession explains the Singapore rules. Where there is a will made abroad, section 5(2) of the Wills Act 1838 accepts it as properly executed if it followed the law of, among others, the place of signing or the testator’s domicile, habitual residence or nationality.

What documents are needed to reseal a foreign grant?

Paragraph 208 of Part 24 of the Practice Directions sets out the filing requirements. The main items are:

• The foreign grant: a copy of the original sealed grant, or a sealed certified true copy issued by the foreign court or authority. An electronic grant may be used if it is the digitally verifiable version from the foreign court’s website, with a solicitor’s certification (para 208(4)(f) and (g)).
• Death certificate: a copy of the Digital Death Certificate if the Singapore Registrar of Births and Deaths has issued one; otherwise a certified true copy of the death certificate (para 208(4)(a) and (b)).
• The will, if any: a certified true copy certified on every page, or, if a foreign court holds the original, a copy certified by that court (para 208(4)(c) and 208(8)).
• Particulars: details of the deceased, applicant and foreign grant; whether the deceased lived or did business in Singapore within 12 months before death; any debts owed to Singapore creditors; and the Singapore property (para 208(11)(j)). For deaths on or after 15 February 2008, a Schedule of Assets is also filed (para 212(1)).
• Power of attorney: if an attorney applies for the foreign grantee, the power must be deposited in the Supreme Court under section 48 of the Conveyancing and Law of Property Act 2005 (para 208(11)(j)(iii)).

The original foreign grant or sealed certified true copy must be submitted to the Probate Counter by 4.30 pm on the Probate Counter’s next operating day after filing, for verification (para 208(8)). For letters of administration, section 49 requires an administration bond, ordinarily with two sureties (section 29 and para 214(1)); the court or registrar may reduce or dispense with the sureties (section 29(3) and para 215). Under section 50, if the deceased resided or carried on business in Singapore within 12 months of death, the court may require security for debts owed to creditors in Singapore.

When do you need a fresh Singapore grant instead?

A fresh application for probate or letters of administration is generally needed where the grant came from a country that is neither in the Commonwealth nor declared, where section 47(4) blocks resealing because of domicile, or where no grant was taken out abroad.

If the deceased died domiciled outside Singapore, paragraph 211(2) of the Practice Directions requires an affidavit of foreign law, or a certificate from a notary practising in that country. The main exceptions are where the executor named in an English-language will applies for probate, or where the Singapore estate is only immovable property and the grant sought is limited to it. The evidence must state who is entitled to administer the estate under the law of the domicile and, for letters of administration, who the beneficiaries are (para 211(3) and (4)). The Singapore steps otherwise follow my guides on probate and letters of administration.

What practical issues slow things down?

• Translations. Allow time if the grant, will or death certificate is not in English. Part 24 refers to a translation “certified by a court interpreter or verified by an affidavit of a person qualified to translate the document” (para 218, which lists Malay words that need no translation).
• Sealed copies. An ordinary photocopy will not do. Ask the foreign court early for a sealed certified true copy.
• Domicile evidence. If domicile is uncertain, expect the court to ask for evidence.
• Sureties and foreign law. Finding sureties, or instructing a foreign lawyer or notary, can take time when the family lives abroad.

Once the grant is resealed or issued, the Singapore assets are collected and distributed as in any estate; see my guide to estate administration after the grant.

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Frequently asked questions

Can I use a foreign grant of probate directly in Singapore?

Not on its own. Under section 47 of the Probate and Administration Act 1934, a grant from a court of probate in any part of the Commonwealth, or in a country or territory declared by Gazette notification, may be resealed by the Family Justice Courts. Once resealed, it has the same effect in Singapore as if granted by the General Division of the High Court. Check that the issuing country qualifies before filing.

What if the grant is from a non-Commonwealth country?

Resealing is available only if the Minister has declared that country or territory by Gazette notification, as has been done for Hong Kong SAR, and the grant was made on or after the date specified. Otherwise, the family will generally need a fresh Singapore grant. Where the deceased died domiciled outside Singapore, this usually requires an affidavit of foreign law or a notary’s certificate.

Does the foreign executor have to come to Singapore?

The Practice Directions contemplate an attorney applying on the grantee’s behalf. The power of attorney must first be deposited in the Supreme Court under section 48 of the Conveyancing and Law of Property Act 2005.

Does a Singapore flat pass under foreign inheritance law?

If there is no will, section 4(2) of the Intestate Succession Act 1967 provides that immovable property is distributed under that Act wherever the deceased was domiciled. Movable property, such as bank balances, follows the law of the domicile. The Act does not apply to the estates of Muslims.

This article is general information, not legal advice. It states Singapore law as at September 2026. Speak to a lawyer about your specific situation.