MAH KIAT SENG v ATTORNEY-GENERAL & 2 Ors

[2023] SGHC 52 High Court (General Division) 3 March 2023 HC/S 256/2020 11 min read

2 cases cited (1 SG, 1 foreign) Cited by 3 cases

Key facts

Court	High Court (General Division)
Decided	3 March 2023
Judge	Philip Jeyaretnam
Charges / claim	Civil Procedure
Counsel	Attorney-General's Chambers, Chin Wan Yew, Rachel, Sarah Shi

Source: [2023] SGHC 52, High Court (General Division), decided 3 March 2023 — eLitigation. Updated 10 July 2026.

Catchwords

Civil Procedure — Costs — Litigant in person

Practice Areas

Civil Procedure

Judges (1)

Philip Jeyaretnam Delivered

Counsel (3)

Attorney-General's Chambers Firm Chin Wan Yew, Rachel Counsel Defendant Sarah Shi Counsel Defendant

Parties (4)

Attorney-General Defendant Mah Kiat Seng Plaintiff Mohamed Rosli bin Mohamed Defendant Tan Thiam Chin Lawrence Defendant

Case Significance

Mah Kiat Seng v Attorney-General and others [2023] SGHC 52 is a costs ruling of the General Division of the High Court (Suit No 256 of 2020), decided by Philip Jeyaretnam J on 3 March 2023 following his earlier substantive decision in [2023] SGHC 14. After Mah Kiat Seng, a litigant in person, succeeded on some claims (including against Mohamed Rosli bin Mohamed for unlawful apprehension and against the police over a search) but failed on others, the court heard the parties on the incidence of costs. The judge put the decision in writing because there is a paucity of authority on the principles for assessing the costs of a litigant in person; the Attorney-General argued costs should follow the event while Mah urged the court to treat the overall "thesis" of wrongful arrest as the measure of success.

[2023] SGHC 52 explained

MAH KIAT SENG v ATTORNEY-GENERAL & 2 Ors ([2023] SGHC 52) is a Singapore judgment decided by the High Court (General Division) on 3 March 2023. It is categorised under Civil Procedure. Within this corpus it has since been cited by 3 other reported Singapore judgments, a measure of how often later decisions have referred to it. This page summarises what the reported decision covers and links the primary sources — the full judgment, the statutes it cites, and the other cases it engages with — so the decision can be read in context. It is reference information, not legal advice, and it does not state the outcome or any holding beyond what the official judgment records.

What is [2023] SGHC 52 about?

MAH KIAT SENG v ATTORNEY-GENERAL & 2 Ors ([2023] SGHC 52) is a High Court (General Division) decision from 2023. Its published catchwords are “Civil Procedure — Costs — Litigant in person”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.

What earlier Singapore cases does [2023] SGHC 52 cite?

Among the in-corpus authorities it refers to are [2023] SGHC 14. The complete list of cases cited, and of later cases that cite this decision, is shown on this page.

How influential is [2023] SGHC 52?

Within this corpus, [2023] SGHC 52 has been cited by 3 later reported Singapore judgments. That count reflects references from other decisions held in this corpus only and is a conservative lower bound on how often the case has actually been cited.

Summary

This was a costs decision following an earlier judgment in Mah Kiat Seng's suit against the Attorney-General and two others, raising how costs for a litigant in person should be assessed. The court held Mah was entitled to costs on his successful claim against one defendant but had to pay costs on his unsuccessful claim against another, assessing his litigant-in-person costs by reference to the Magistrate's Court scale. The result was a net balance of costs owing to the defendants, against which his damages could be set off.

What did Mah Kiat Seng v Attorney-General [2023] SGHC 52 decide?

The judgment is Philip Jeyaretnam J's written costs ruling of 3 March 2023 in Suit No 256 of 2020, following his substantive decision in [2023] SGHC 14. It addresses how costs are assessed for a litigant in person, an area with little authority.

Why did the court issue a written costs decision in Mah Kiat Seng v Attorney-General ([2023] SGHC 52)?

Philip Jeyaretnam J explained he put the costs decision in writing because there is a paucity of authority on the principles for assessing the costs of a litigant in person, an issue that arose after Mah succeeded on some claims but failed on others.