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)

Outcome

Appeal allowed

We allowed the appeal.

Source: [2025] SGCA 2, Court of Appeal, decided 13 January 2025. Read directly from the judgment.

Key facts

Court Court of Appeal
Decided
Judges Debbie Ong Siew Ling, Sundaresh Menon, Tay Yong Kwang
Charges / claim Legal Profession
Outcome Appeal allowed
Counsel Attorney-General's Chambers, Bajwa & Co, Bih Li & Lee LLP, Global Law Alliance LLC, Providence Law Asia LLC, Abraham Vergis, Axl Rizqy, Chng Luey Chi, Darrell Low Kim Boon, Ho Jiayun, Khoo Boo Jin, Ng Rui Wen, Petrina Tan Heng Kiat, Ragbir Singh s/o Ram Singh Bajwa, Shi Pei-Yi Sarah, Spencer Chew

Source: [2025] SGCA 2, Court of Appeal, decided — eLitigation. Updated .

Catchwords

Practice Areas

Judges (3)

Counsel (16)

Parties (3)

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.

[2025] SGCA 2 explained

ATTORNEY-GENERAL v SHANMUGAM MANOHAR & Anor ([2025] SGCA 2) is a Singapore judgment decided by the Court of Appeal on 13 January 2025. It is categorised under Legal Profession. It is a recent decision; within this corpus no later judgment has cited it yet. 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 [2025] SGCA 2 about?

ATTORNEY-GENERAL v SHANMUGAM MANOHAR & Anor ([2025] SGCA 2) is a Court of Appeal decision from 2025. 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 [2025] SGCA 2 consider?

The judgment refers to Criminal Procedure Code (Cap 68), Evidence Act (Cap 97), Legal Profession Act (Cap 161), and Supreme Court of Judicature Act (Cap 322). The statutes cited are listed in full on this page, each linking to its primary text.

What earlier Singapore cases does [2025] SGCA 2 cite?

Among the in-corpus authorities it refers to are [2024] SGHC 28. The complete list of cases cited, and of later cases that cite this decision, is shown on this page.

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 ([2025] SGCA 2)?

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

Cases Cited (21)

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

Related cases

Other Singapore judgments involving the same parties or counsel.

Referenced in

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGCA 2)