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Chan Hiang Leng Colin v Public Prosecutor

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Chan Hiang Leng Colin v Public Prosecutor
CourtSingapore High Court
Full case nameChan Hiang Leng Colin and others v Public Prosecutor
Decided15 September 1994
Citation[1994] SGHC 207
Case history
Prior action???
Related actionsChan Hiang Leng Colin & Ors v Minister for Information and the Arts [1996] 1 S.L.R. 609, C.A.; [1990] 1 S.L.R.(R) 347, C.A.; Chan Hiang Leng Colin and others v Minister for Information and the Arts [1995] 2 S.L.R.(R.) 627, H.C.
Court membership
Judge sittingYong Pung How C.J.
Case opinions
Exercise of discretion by President and Minister for Home Affairs under ss. 8 and 10 of the Internal Security Act subject to judicial review by a court as an objective rather than subjective test applies.

The case of Chan Hiang Leng Colin v Public Prosecutor[1]was a Singapore High Court case that dealt with restrictions on an individual’s fundamental liberties under Part IV of the Constitution of the Republic of Singapore when such liberties come into conflict with state or public interests.

The case centred on the restriction of the appellant’s fundamental liberties– his freedom of religion– with the aim of preserving a state interest in national service.[2]

This case, which was presided over by Yong Pung How CJ (as he then was), established the Singapore courts’ position that the fundamental liberties of an individual are subject to the interests of the state and the public.

Facts

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Background

The Jehovah’s Witnesses is a religious group that refuses to engage in any political or national practices, such as saluting the flag or performing national service. This was deemed prejudicial to the public welfare and good order of Singapore, and on 14 January 1972, the government passed orders to deal with the threat to public order.

Firstly, Gazette Notification No. 123 (“Order 123”) prohibited publications related to the doctrine of the Jehovah’s Witnesses sect, and was made by the Minister of Culture pursuant to s 3 of the Undesirable Publications Act (“UPA”).[3]

These publications were by the Watch Tower Bible & Tract Society (“WTBTS”), the parent body of the Jehovah’s Witnesses. [4]

Additionally, Gazette Notification No. 179 (“Order 179”) ordered the dissolution of the Singapore Congregation of Jehovah’s Witnesses by the Minister for Home Affairs pursuant to his powers under s 24(1) of the Societies Act (“SA”).[5]

Facts of the Present Case

The Appellants were members of the Jehovah’s Witnesses religious group. On 2 July 1992, police seized publications from the Appellants. 13 of the publications were those prohibited under Order 123.

The Appellants were charged under Order 123 for possession of publications by the WTBTS, an offence punishable under s 4(2) of the UPA.

Issues raised during Appeal

Trial Judge’s Decision

The case was first heard in the District Court. There, the Accused had contended that Order 123 was ''ultra vires'', or beyond the powers of the UPA and Article 15 of the Constitution of Singapore ("Art. 15"), which enshrines the freedom of religion[6]. The trial judge dismissed the preliminary objections, finding that Order 123 was valid and constitutional, as the order concerned the public interest and was permitted under s 3(1) of the UPA. Accordingly, the trial judge convicted the Accused for possessing the banned publications. The Accused appealed against the trial judge's decision.

Appeal to the High Court

The Appellants raised three main grounds of appeal regarding administrative and constitutional law issues. They are:

  1. Whether Order 179 was unconstitutional and ultra vires to s 24(1)(a) of the SA.
  2. Whether Order 123 was ultra vires the UPA or unconstitutional.
  3. Whether Order 123 was unreasonable and disproportionate.

Judgment

Procedural Issue: Whether the High Court could hear constitutional matters in its appellate capacity

In light of the arguments raised by the Appellants on appeal, one preliminary issue that the High Court had to determine was whether it could, in its appellate capacity, hear the appeal which involved constitutional matters.

A High Court could hear the constitutional issues only in its ordinary capacity. However, the High Court here was sitting as an appellate court in a criminal proceeding, and its powers were necessarily limited[7] to that of the Subordinate Court from which the appeal emanated [8]. To this end, the District Court did not have the power to address the constitutional issues raised[9] and the High Court could not hear the constitutional matters at appeal in its appellate capacity.

However, the court recognised that both parties agreed on the court’s competence in determining constitutional issues. The Appellants had also raised issues regarding the constitutionality of the government regulations, and if the regulations were to be proven invalid, it would afford the Appellants a substantive defence to the charges and would affect the delivery of justice.

Therefore, the High Court made an exception and heard the case in its appellate jurisdiction. In doing so, the court emphasised that the constitutional issues raised were of significant importance and the facts of the case was considered to be “exceptional”.[10]

Whether Order 179 was unconstitutional and ultra vires s 24(1)(a) of the SA

At the outset, Yong CJ emphasized that the court will not question the merits of the exercise of the ministerial discretion. In this regard, “there can be no enquiry as to whether it was a correct or proper exercise or whether it should or ought to have been taken”.[11] There was a presumption of constitutionality for the Orders, and the burden was on the Appellant to prove that they were unconstitutional or ultra vires.[12]

The Appellants contended that under Art 15(4), restrictions on the right of freedom of religion could be imposed only if public order, public health or morality is affected, and s 24(1)(a) of the Societies Act provides for registered organizations to be dissolved only if they threaten public peace, welfare or good order.[13]

The Appellants therefore submitted that there had to be a clear and immediate danger to public order before freedom of religion can be circumscribed. Consequently, since the activities of Jehovah’s Witnesses posed no such threat, the de-registration order contravened Art 15(1) of the Constitution and was ultra vires.[14]

However, Yong CJ rejected the Appellant's argument, as he believed that the mere ‘possibility of trouble over religious beliefs’ is sufficient cause for Ministers to take action. To this end, the danger does not have to be clear and immediate.[15]

Also, Yong CJ held that any religious belief and practice which offends the ‘sovereignty, integrity and unity of Singapore’ must be restrained.[16] While there was no dispute that Jehovah’s Witnesses were law-abiding citizens and their religious activities held no political agendas, their refusal to perform national service was, in the Minister’s view, contrary to public peace, welfare and good order.[17] In this regard, Yong CJ considered the concerns of the Assistant Director of Manpower of the Ministry of Defence – if the beliefs of Jehovah’s Witnesses were recognized, a select group of people would enjoy the social and economic benefits of their country, without having to share in the responsibility of defending the community’s social and political institutions.[18]

Since the court had no capacity to review the merits of the decision and conclude whether Jehovah’s Witnesses were a threat to public order, it was sufficient that the Minister had made Order 179 with the view that the existence of Jehovah’s Witnesses, which forbid national service, was contrary to public peace, welfare and good order.[19] The judge also remarked that notion of public peace, welfare and good order as in the Societies Act is similar to the concept of public order as envisaged under Art 15(4) of the Constitution.[20] Thus the rationale of maintaining public order behind Order 179 fell within the permitted categories spelt out in both s24(1)(a) and Art 15(4) respectively.

Whether Order 123 was ultra vires s 3(1) of the Undesirable Publications Act (Cap. 338, 1998 Rev. Ed.)

S 3(1) of UPA confers a discretion on the Minister to order the prohibition of any publication if he opined that such publications are contrary to the public interest.[21] Again, the court will not review the merits of the Ministerial discretion. Since the Minister had decided that the existence of Jehovah’s Witnesses would be ‘prejudicial to public welfare and good order’, which clearly relates to public interest, Order 123 was based upon relevant considerations and not ultra vires s 3(1) of the UPA.[22] Moreover, Yong CJ opined that Order 123 seek to reinforced the ban on Jehovah Witnesses' movement pursuant to Order 179.[23]


Hence, the Appellant’s constitutional and administrative challenges were dismissed on the same basis that once the considerations of the executive were in relation to public interest, “there could therefore be no objection that the prohibition order was made on an irrelevant ground”.[24]

Fettering of Discretion

Appellants contended that Minister had fettered his discretion when making Order 123. They alleged that publications were banned because of the de-registration of the Jehovah Witnesses Sect and not because Minister was satisfied of its undesirability.[25]

Yong CJ, refering to the affidavit of the Minister for Culture, held that Order 123 was made after the Government had been satisfied that the teachings and beliefs contained in the publications of WTBTS were contrary to the public interest. The teachings of the Jehovah Witness were viewed as being prejudicial to the Government’s effort in nation building. Hence Minister rightly exercised his discretion to prohibit such publications.[26]

Whether Order 123 was unconstitutional

The High Court did not explicitly deal with the constitutionality of Order 123 despite including it as one of the grounds of appeal.[27]

Evaluation of the Judgment in relation to Orders 179 and 123

Subjective discretion

It appears that the court allowed the matter to be decided by the subjective discretion of the Minister(reference to colin p?). The only explanation given for de-registration was that the refusal to perform national service was contrary to public interest. There was however no requirement for the executive to elaborate on how exactly a failure to perform national service would be contrary to public interest. The Court accepted the executive’s discretion to derogate a fundamental right without a close scrutiny as to the executive’s rationale and explanations.

Interpretation of the Constitution

Art 15(1) lays down the general principle sanctifying the freedom of religion, and Art 15(4) allows an exception to the general principle if the religious act is contrary to any law relating to public order, health or morality.

Yong CJ stated that acts flowing from religious beliefs must ‘conform’ to general legislation (reference to colin [64]). This implies that derogating legislations are presumptively constitutional and Art 15(4) restrictions would take precedence over fundamental liberties. This has been criticised by Prof Thio Li-ann, that “exceptions swallowing up general principles can make a mockery of any constitutional liberty”

Definition of 'Public Order'

Although the court held that the activities of the Jehovah Witness were against “public order”, Yong CJ did not engage in a detailed explanation of how their activities disrupt public order. 'Public Order' was also not defined in the judgment.

Counsel for the Appellants had cited the Malaysian case of Tan Boon Liat v Menteri Hal Ehwal Dalam Negeri, Malaysia [1976] 2 MLJ 83 [28] which designed a test to determine “public order”:

The test to be adopted in determining whether an act affects law and order or public order is this: Does it lead to disturbance of the current of life of the community so as to amount to disturbance of the public order or does it affect merely an individual leaving the tranquility of the society undisturbed?

While Yong CJ acknowledged counsel's submissions, he did not address the suggested test. Instead, he went on to discredit the “clear and immediate danger test”. Yong CJ held that to allow the possibility of trouble over religious beliefs to exist and wait until trouble is about to break out before taking action would be “pathetically naïve [and] grossly incompetent” of any administration.[Chan Hiang Leng Colin and others v Public Prosecutor [1994] 3 SLR(R) CITE at 59]


Professor Thio Li-Ann has argued that this ‘nip in the bud’ approach spells out dire consequences for the preservation of civil liberties. She notes that this “exaltation of efficiency over all other interests” creates a mala fides situation which allows for the relevant decision-makers to simply point to a low standard of a ‘possibility’ of trouble before curtailing a constitutional liberty. She advocates that at least a certain degree of possible danger must be established prior to such a curtailment. Otherwise, she argues, the source of rights would become the state and not something intrinsic to one’s humanity, which she sees as a “flimsy basis for human rights.”[Supra, n 3 at 89-90]

In thus regard, it appeared that the court departed from the typical test for ‘public order’, which usually involved some display of violence. It has been said that a more extensive conception of ‘public order’ was enunciated. This conception was that public order requires the curtailing of a “passive threat” to a governmental policy considered to be the “cornerstone of national security.” This was regarding a lack of participation in national service. [Thio Li-Ann, “The Secular Trumps the Sacred: Constitutional Issues Arising From Colin Chan v Public Prosecutor”, (1995) Singapore Law Review 16 at p.76.]

No Balancing Exercise Performed

The court did not conduct any balancing exercise in weighing the fundamental liberty against public interest. Instead, they adopted a Categorisation approach where the presence of any factor indicated in Art 15(4) would be accepted as conclusive regardless of its impact on public order. This reveals a judicial deference to the ministerial judgment in issuing orders curtailing constitutional liberties. In this case, the ‘right of religious freedom was not given due weight’ as there was no judicial pronouncement on the value of one’s religion.

In Singapore, utilitarian rather than dignitarian considerations pervade throughout judicial reasoning. Professor Thio Li-ann(ref ) has commented that the court by subscribing to ministerial discretion, abdicates its “watchdog role over individual rights”. if there is potential abuse of individual rights, there might not be a strong judicial will to check the abuse.

Whether Order 123 was unreasonable and disproportionate

The blanket ban on all WTBTS publications was allegedly unreasonable and excessive. Council for the Appellants contended that Order 123 was excessive and sweeping because WTBTS also published other publications that were not contrary to public interest, such as the King James Bible. [29]However, all publications by WTBTS were banned under Order 123 regardless of its content.

The court held that the order to prohibit all publications by WTBTS was not excessive. The Minister’s actions were to stop all publication by WTBTS, and any order other than a total blanket order would have been impossible to monitor administratively.[30] Therefore the fact that one publication was unobjectionable as to its contents did not make the ban unreasonable per se.[31]

Yong CJ also held that the orders were not irrational or disproportionate. He accepted the Minister’s view that the Jehovah Witnesses’ refusal to perform nation service was prejudicial to national security. In this regard, the activities of the Jehovah’s Witnesses were properly restricted on the basis that they were against “public order” and the prohibition on their publications was a natural consequence in view of “public interest”.[32]

Evaluation

Proportionality as a ground of judicial review has been excluded in Singapore’s constitutional law. In Chng Suan Tze(Chng Suan Tze v Minister for Home Affairs and others and other appeals [1988] SGCA 16); the Court of Appeal held there was no independent ground for proportionality under judicial review and any issue of proportionality was subsumed under irrationality. (Colin 77.)

Therefore, in Colin, no consideration was given to issues of proportionality or that the ban being unreasonable and over-inclusive. It appears that so long as the Minister’s motives for the Orders are based on considerations of national security and “good order”, the nature of the ban or its scope is not reviewable. This will give the Minister excessive powers.


In addition, Professor Thio Li-ann criticized the prioritisation of administrative convenience and efficiency over individual's fundamental rights. She argued that this has allowed 'state interests to trump rights rather than vice versa'.


Whether there was a breach of natural justice

Relevant Facts

One of the submissions raised by the Appellants was that the prohibition and deregistration orders were made in breach of the natural justice principle of ''audi alteram partem'', or “hearing the other side”. They contended that the orders were made without any notice or hearing, and they were not given an opportunity to explain or correct the allegations against them.

The Appellants contended that natural justice asserts the right to be heard before one’s interest is violated, and that this is an essential aspect of the rule of law and the equal treatment by the law of all citizens. Depriving them of the right to a fair hearing is arguable a violation[33] of Art 12 of the constitution, which affords equal protection of all persons before the law.

Holding: Whether the prohibition and de-registration orders were made in breach of natural justice

The court held, firstly, upon examination of s3 UPA and s24(1) SA, that there is no express requirement for the relevant Minister to have given the affected parties such a right to be heard before the orders were made.[34]

The court held that there was no room for the Appellants’ contention that the principles of natural justice had to be complied with fully. The orders were made with respect to both the public interest and the public order and the objective was clearly for the preservation of national security. The court affirmed Lord Denning MR’s conclusion [35] that in such situations, the ordinary principles of natural justice had to be modified accordingly to accommodate public interest.[36]

It was notably also held that because the basis for the Minister’s conclusion clearly could not be disputed, there was no need for any hearing or inquiry as no purpose would have been achieved. This was with regard to his decision that the Jehovah's Witnesses doctrine of the prohibition of military service for its adherents was contrary to national security and thus contrary to public order and interest. It was held that the Appellants had not shown that the Minister had based his conclusions on false or unfounded facts; unless the grounds were irrelevant, the court could not interfere with the Minister’s opinion since his discretionary power was exercised within statutory limitations.[37]

Evaluation of the Court’s Position

The principle of audi alteram partem is known as a cardinal principle of natural justice, that no person shall be condemned unless he has been given prior notice of the allegations against him and a fair opportunity to be heard.[38] In general, Art 12(1)[39] protects rights such as this. It has been referred to in Singapore as one of the two rules that make up the administrative law rules of natural justice.[40] tryy [41]

tryyy However, where public interest is at stake, the English courts have taken a modified approach to the applicability of the principles of natural justice. In Ex Parte Hosenball, Lord Denning referred to Lord Reid's holdings in Ex parte Secretary of State for Home Department.[Reg. v. Lewes Justices, Ex parte Secretary of State for Home Department [1973] A.C. 388.] There, it was held that there was a public interest in withholding certain documents from being produced at another court proceeding, as the potential of those documents being withheld prevented the public body from properly discharging their public duty. Lord Reid stated that the requirement for natural justice in that case was clearly outweighed by the public interest, thus the public body was entitled to assert that public interest.[42] Thus, Lord Denning in Ex Parte Hosenball held that owing to the national security interest in withholding from Hosenball information regarding allegations against him, there was no need to comply with the principle audi alteram partem.

The approach taken in Chan hence follows the general principle tthat public interest prevails over rules of natural justice. Prior notice and the opportunity to be heard before the orders need not be given in the interest of national security.

It has been argued, however, to present a problem that the Minister simply needs to state that there is a national security interest, upon which the rules of natural justice can immediately be compromised. Professor Thio Li-ann has argued that it may be advisable to have a duty to give reasons to establish an objective validity to an order imposed when important constitutional rights such as the freedom to religion are being curtailed.[CITE] It seems that if such a duty was required, then it would be more justified to allow rules of natural justice to be subverted by public interest grounds.

Whether the orders were disproportionate to the interests of the state

???!!!!! WHERERR

Four Walls Doctrine

The Appellants also contended that the ban was a violation of the international declaration of human rights.[43]

The Court of Appeal held that the issues would be best resolved by a “consideration of the provisions of the Constitution, the Societies Act and the UPA alone.”[44] There was however no consideration of the international declaration of human rights in the judgement.

The Court of Appeal here endorsed the four walls approach in Government of the State of Kelantan v. Government of the Federation of Malaya 1963 and imported the principle into Singapore common law. [45]

In "Kelantan", Thomson CJ had commented that: [T]he Constitution is primarily to be interpreted within its own four walls and not in the light of analogies drawn from other countries such as Great Britain, the United States of America or Australia.[46]

Yong CJ noted that the “social conditions” in Singapore were “markedly different” from that in the U.S., concluding, “On this basis alone, I am not influenced by the various views as enunciated in the American cases cited to me but instead must restrict my analysis of the issues here with reference to the local context.”[47]

CA rejected the American cases dealing with freedom of religion on the basis that the Singapore Constitution does not prohibit the ‘establishment’ of any religion unlike the American one with its anti-establishment clause.[48]


Application of the 4 walls doctrine in other cases

Consequently, the four walls doctrine was affirmed in subsequent cases.

In Nappalli Peter Williams v. Institute of Technical Education [49], Tan Lee Meng J commented that “There are differences between the American position and the Singapore constitution and that social conditions in Singapore are markedly different from those in the US.” However, little explanation was given as to how the social conditions are different.

There was more active judicial engagement with relation to international law as opposed to the decisive disapproval as in Colin in the case of Nguyen Tuong Van v PP[50]

In the case of Nguyen, the court had commented that “Non-binding resolutions such as the Universal Declaration of Human Rights (“UDHR”) have no legal force in national law, unless they embody customary international law. Singaporean courts may apply customary international norms unless they are contrary to local statute.”[51]

The court had proceeded to analyze how established the international norms are before deciding if they should be applied in Singapore, revealing a more open-minded approach to international law.


Adopting Foreign Jurisdictions in the Singapore High Court

The Singapore High Court has been both dismissive and receptive of foreign case law, depending on whether the case law will aid in supporting its decisions.

Yong CJ had first explained that the decision in Colin should rely purely on domestic law. However, he went on to approve the reasoning of an Australian case, Adelaide Company of Jehovah's Witnesses v. Commonwealth of Australia[52], with respect to limitations on religious freedom of Jehovah's Witnesses.[53]. This seems to imply a judicial choosing of foreign cases to support their own decisions, instead of a complete refusal to regard foreign jurisdictions.


Sub-subsection

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SUMMARY

statist conclusion.

See also

Notes

  1. ^ Chan Hiang Leng Colin and others v Public Prosecutor [1994] SGHC 207
  2. ^ Colin Chan, p. 212, para. 11.
  3. ^ Undesirable Publications Act (Cap. 338, 1985 Rev Rev. Ed.) ("UPA"), s. 3.
  4. ^ Colin Chan, p. 210.
  5. ^ Societies Act (Cap. 311, 1985 Rev Rev. Ed.), s. 24 (1).
  6. ^ Singapore Constitution, Art. 15.
  7. ^ PP v Lee Meow Sim Jenny[1993]3 S.L.R.(R.) 369 at para. 13- 14.
  8. ^ Colin Chan, p.212, para.14
  9. ^ Chan Hiang Leng Colin, p. 216-217, para. 8.
  10. ^ Colin Chan, p. 225, para. 33.
  11. ^ Chan Hiang Leng Colin, p. 232, para. 55.
  12. ^ Colin Chan, p. 232, para. 56.
  13. ^ Colin Chan, p. 233, para. 58.
  14. ^ Colin Chan, p. 233, para. 59.
  15. ^ Colin Chan, p. 233, para. 59.
  16. ^ Colin Chan, p. 235, para. 64.
  17. ^ Colin Chan, p. 237, para. 68.
  18. ^ Colin Chan, p. 235, para. 65.
  19. ^ Colin Chan, p. 237, para. 68.
  20. ^ Colin Chan, p. 237, para. 68.
  21. ^ Chan Hiang Leng Colin, p. 238, para. 70.
  22. ^ Chan Hiang Leng Colin, p. 238, para. 70.
  23. ^ Chan Hiang Leng Colin, p. 238, para. 70.
  24. ^ Chan Hiang Leng Colin, p. 238, para. 70.
  25. ^ Chan Hiang Leng Colin, p. 238, para. 73.
  26. ^ Chan Hiang Leng Colin, p. 239, para. 74.
  27. ^ Chan Hiang Leng Colin, p. 230, para. 48.
  28. ^ Tan Boon Liat v Menteri Hal Ehwal Dalam Negeri, Malaysia[1976] 2 M.L.J. 83
  29. ^ Chan Hiang Leng Colin, p. 238, para. 71.
  30. ^ Chan Hiang Leng Colin, p. 238, para. 72.
  31. ^ Chan Hiang Leng Colin, p. 238, para. 72.
  32. ^ Chan Hiang Leng Colin, p. 240, para. 78.
  33. ^ Secular, p. 44.
  34. ^ Colin Chan, p. 239, para. 75.
  35. ^ R v Secretary of State for Home Affairs; ex parte Hosenball [1977] 1 WLR 766 at 779.
  36. ^ Colin Chan, p. 239, para. 75.
  37. ^ Colin Chan, p. 239- 240, para. 76.
  38. ^ Tan Tiang Hin Jerry v Singapore Medical Council [2000]1 S.L.R.(R.) 553 at para. 23.
  39. ^ Singapore Constitution, Art. 12(1).
  40. ^ Yong Vui Kong v Attorney-General [2011] 2 S.L.R. 1189 at para. 88.
  41. ^ Associated Provincial Picture Houses v. Wednesbury Corporation [1947] EWCA Civ 1, [1948] 1 K.B. 223, Court of Appeal (England and Wales).
  42. ^ "Lewes Justices", para. 402.
  43. ^ Colin Chan, p. 232, para.54.
  44. ^ Colin Chan, p. 232, para.54.
  45. ^ Government of the State of Kelantan v. Government of the Federation of Malaya [1963] MLJ 355.
  46. ^ Colin Chan, p. 231, para.51.
  47. ^ Colin Chan, p. 231, para.53.
  48. ^ Colin Chan, p. 231, para.53.
  49. ^ Nappalli Peter Williams v. Institute of Technical Education[1998] S.G.H.C. 351, para. 42.
  50. ^ Nguyen Tuong Van v PP 1 Sing. L. Rep. 103 (C.A. 2005), para. 126-27.
  51. ^ Nguyen, para. 126.
  52. ^ Adelaide Company of Jehovah's Witnesses v. Commonwealth of Australia(1943) 67 C.L.R. 116 (Austl.)
  53. ^ Colinat 234, para. 60.
  54. ^ Remember to add a citation at the end of your quotation.

Further reading

Articles and websites

  • Pillai, K. Muralidharan; Luo, Qinghua (2009), "Revisiting the High Court's Revisionary Jurisdiction to Enhance Sentences in Criminal Cases", Singapore Academy of Law Journal, 21: 135–160.
  • Singapore court system, Law Society of Singapore, retrieved 26 December 2009.
  • Tan, Eugene; Chan, Gary (13 April 2009), "The Judiciary", The Singapore Legal System, Singapore Academy of Law, retrieved 26 December 2009.

Books

  • Chan, Helena H[ui-]M[eng] (1995), "The Judiciary", The Legal System of Singapore, Singapore: Butterworths Asia, pp. 41–68, ISBN 978-0-409-99789-7 (pbk.) {{citation}}: Check |isbn= value: invalid character (help).
  • Kwek, Mean Luck [et al.], eds. (2006), Hall of Justice: Supreme Court Singapore, Singapore: Supreme Court of Singapore, ISBN 978-981-05-5356-2 {{citation}}: |first= has generic name (help)CS1 maint: multiple names: authors list (link).
  • Tan, Kevin Y[ew] L[ee] (2011), "Without Fear or Favour: The Judiciary", An Introduction to Singapore's Constitution (rev. ed.), Singapore: Talisman Publishing, pp. 107–131, ISBN 978-981-08-6456-9 (pbk.).
  • Tan, Kevin Y[ew] L[ee]; Thio, Li-ann (2010), "The Judiciary", Constitutional Law in Malaysia and Singapore (3rd ed.), Singapore: LexisNexis, pp. 505–630, ISBN 978-981-236-795-2 (hbk.).
  • Thian, Yee Sze; Chong, Chin Chin; Lim, Sharon (2002), In Session: Supreme Court Singapore: The Building, her Heritage and her People, Singapore: Supreme Court of Singapore, ISBN 978-981-047-671-7.
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