ATTORNEY-GENERAL v SHANMUGAM MANOHAR & Anor

[2025] SGCA 2 Court of Appeal 13 January 2025 • CA/CA 18/2024 • 49 min read
21 cases cited (19 SG, 2 foreign)

Catchwords

Legal Profession — Disciplinary proceedings — Review of determination of disciplinary tribunal

Practice Areas

Legal Profession

Judges (3)

Debbie Ong Siew Ling Delivered Sundaresh Menon Coram Tay Yong Kwang Coram

Counsel (16)

Attorney-General's Chambers Firm Bajwa & Co Firm Bih Li & Lee LLP Firm Global Law Alliance LLC Firm Providence Law Asia LLC Firm Abraham Vergis Counsel Respondent Axl Rizqy Counsel Respondent Chng Luey Chi Counsel Appellant Darrell Low Kim Boon Counsel Respondent Ho Jiayun Counsel Appellant Khoo Boo Jin Counsel Appellant Ng Rui Wen Counsel Respondent Petrina Tan Heng Kiat Counsel Respondent Ragbir Singh s/o Ram Singh Bajwa Counsel Respondent Shi Pei-Yi Sarah Counsel Appellant Spencer Chew Counsel Respondent

Parties (3)

Attorney-General Appellant The Law Society of Singapore Respondent Shanmugam Manohar Respondent

Case Significance

[2025] SGCA 2 is a Court of Appeal decision dated 13 January 2025 concerning Legal Profession, specifically addressing disciplinary proceedings. The judgment was delivered by Debbie Ong Siew Ling, with Sundaresh Menon and Tay Yong Kwang on the coram. The case was brought by Attorney-General (appellant) against The Law Society of Singapore and others (respondent). Legal representation was provided by Attorney-General's Chambers and Bajwa & Co. The judgment cites 21 cases (19 Singapore, 2 foreign) and references 4 statutory provisions, including the Criminal Procedure Code, the Evidence Act, and the Legal Profession Act.

Summary

The Attorney-General appealed against the determination of a Disciplinary Tribunal that had acquitted advocate and solicitor Shanmugam Manohar of charges relating to the practice of touting — specifically, paying a non-lawyer referral fees of $600-$800 per case for client referrals to his firm. The Court of Appeal found that the Disciplinary Tribunal had failed to discharge its statutory duty to hear and investigate the touting charges. The appeal was allowed and a fresh Disciplinary Tribunal was ordered to be constituted.

What was decided in [2025] SGCA 2?

[2025] SGCA 2 (ATTORNEY-GENERAL v SHANMUGAM MANOHAR & Anor) is a Court of Appeal decision from 13 January 2025 addressing Legal Profession, specifically disciplinary proceedings. The judgment was delivered by Debbie Ong Siew Ling.

Who were the parties in ATTORNEY-GENERAL v SHANMUGAM MANOHAR & Anor?

The appellant in [2025] SGCA 2 was Attorney-General, and the respondent was The Law Society of Singapore, Shanmugam Manohar. Legal representation included Bajwa & Co and Attorney-General's Chambers. The case was decided on 13 January 2025 in the Court of Appeal.

Which judge decided [2025] SGCA 2?

[2025] SGCA 2 was delivered by Debbie Ong Siew Ling in the Court of Appeal on 13 January 2025. Sundaresh Menon and Tay Yong Kwang also sat on the coram. The case concerned Legal Profession.

What cases and statutes does [2025] SGCA 2 cite?

[2025] SGCA 2 cites 21 prior decisions, including 2 from foreign jurisdictions. It references Criminal Procedure Code, Evidence Act, Legal Profession Act.

Statutes Cited

Criminal Procedure Code (Cap 68)
s 22
Evidence Act (Cap 97)
s 32(1)(j)
Legal Profession Act (Cap 161)
Supreme Court of Judicature Act (Cap 322)

Cases Cited (21)

SG (1)
[2024] SGHC 28
SLR (18)
[1989] 2 SLR(R) 633 [1998] 2 SLR(R) 905 [2006] 1 SLR 484 [2006] 4 SLR(R) 934 [2007] 1 SLR(R) 85 [2007] 4 SLR(R) 377 [2008] 4 SLR(R) 1058 [2009] 1 SLR(R) 753 [2010] 3 SLR 390 [2011] 2 SLR 1279 [2020] 4 SLR 858 [2021] 1 SLR 1135 [2021] 1 SLR 874 [2021] 1 SLR 926 [2021] 2 SLR 1013 [2021] 3 SLR 600 [2021] 4 SLR 382 [2022] 3 SLR 731
MY (2)
[1950] MLJ 113 [1985] 2 MLJ 35

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGCA 2)