ATTORNEY-GENERAL v SHANMUGAM MANOHAR & Anor
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Case Significance
Attorney-General v Shanmugam Manohar & Anor [2024] SGHC 28 was decided by Hoo Sheau Peng J in the General Division of the High Court (Originating Application No 541 of 2023), with judgment reserved and delivered on 31 January 2024 following a hearing on 26 September 2023. The Attorney-General applied under s 97(1)(a) of the Legal Profession Act 1966 (2020 Rev Ed) to review a determination of the Disciplinary Tribunal in DT/23/2022, made under s 93(1)(b), dated 27 April 2023. The Tribunal had determined that there was no cause of sufficient gravity for disciplinary action under s 83 against the first respondent, Mr Shanmugam Manohar, concerning the Attorney-General's complaint dated 2 July 2018; the Council of the Law Society accepted that determination on 15 May 2023. Having considered the submissions, the court dismissed the application.
[2024] SGHC 28 explained
ATTORNEY-GENERAL v SHANMUGAM MANOHAR & Anor ([2024] SGHC 28) is a Singapore judgment decided by the High Court (General Division) on 31 January 2024. It is categorised under Legal Profession. Within this corpus it has since been cited by 2 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 [2024] SGHC 28 about?
ATTORNEY-GENERAL v SHANMUGAM MANOHAR & Anor ([2024] SGHC 28) is a High Court (General Division) decision from 2024. Its published catchwords are “Legal Profession — Disciplinary proceedings — Review of determination of disciplinary tribunal”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.
Which legislation does [2024] SGHC 28 consider?
The judgment refers to Legal Profession Act (Cap 161). The statutes cited are listed in full on this page, each linking to its primary text.
How influential is [2024] SGHC 28?
Within this corpus, [2024] SGHC 28 has been cited by 2 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 an application by the Attorney-General under section 97(1)(a) of the Legal Profession Act 1966 to review a determination of a Disciplinary Tribunal, which had found that there was no cause of sufficient gravity for disciplinary action against the first respondent, Mr Shanmugam Manohar. The Attorney-General sought to have the determination set aside and asked that the Law Society of Singapore be directed to apply for the appointment of another disciplinary tribunal. The General Division of the High Court, per Hoo Sheau Peng J, disagreed with the Attorney-General on the grounds raised and dismissed the application.
What did the High Court decide in Attorney-General v Shanmugam Manohar [2024] SGHC 28?
Hoo Sheau Peng J dismissed the Attorney-General's application to review and set aside the Disciplinary Tribunal's determination in DT/23/2022. The Tribunal had found no cause of sufficient gravity for disciplinary action under s 83 of the Legal Profession Act against Mr Shanmugam Manohar.
What statutory provision did the Attorney-General rely on in [2024] SGHC 28?
The Attorney-General applied under s 97(1)(a) of the Legal Profession Act 1966 (2020 Rev Ed) to review the Disciplinary Tribunal's determination made under s 93(1)(b), and sought to set it aside under s 97(4)(b)(ii) so a fresh tribunal could be appointed.
Who were the parties in Attorney-General v Shanmugam Manohar [2024] SGHC 28?
The applicant was the Attorney-General. The first respondent was Mr Shanmugam Manohar, an advocate and solicitor, and the second respondent was the Law Society of Singapore. The matter was Originating Application No 541 of 2023, decided on 31 January 2024.
Statutes Cited
Cases Cited (8)
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Statutes interpreted in this judgment
Legal concepts & references
Judgment
Read the full judgment on the official Singapore Courts portal.
Read on eLitigationSource: eLitigation ([2024] SGHC 28)