THE LAW SOCIETY OF SINGAPORE v WILLJUDE VIMALRAJ S/O RAYMOND SURAS

Facts

The Law Society of Singapore applied to the Court of 3 Supreme Court Judges in Originating Application No 1 of 2025 to have Willjude Vimalraj s/o Raymond Suras struck off the Roll of Advocates and Solicitors. He was admitted on 10 February 2021.

Before that, while serving as an investigating officer in the Singapore Police Force, he forged witness statements in criminal investigations: he wrote statements from notes of phone interviews, backdated them, added false signatures and fictitious accounts, and in some cases wrote them without contacting the witnesses. After resigning from the police, he swore in his admission affidavit dated 22 December 2020 that he was not the subject of any pending criminal investigation, although he had been served a Notice of Investigation for forgery. On 20 June 2024 he pleaded guilty to nine forgery charges and one charge of intentionally giving false evidence in a judicial proceeding, with 29 further forgery charges taken into consideration, and was sentenced to 25 months' imprisonment. The Attorney-General's Chambers asked the Law Society to act under s 94A(1) of the Legal Profession Act 1966.

Issues

1. Whether due cause was shown under s 83(2)(a) of the Legal Profession Act.
2. Whether it mattered that the offences were committed before his admission.
3. Whether s 16(4) should be used instead for the false admission affidavit.
4. Whether any exceptional circumstances made striking off disproportionate.

Holding

The court, in an ex tempore judgment delivered by Sundaresh Menon CJ, granted the application and ordered that the respondent be struck off the Roll. It awarded the Law Society costs of $6,000 and disbursements of $1,110.75.

Reasoning

Due cause. A conviction implying a defect of character shows due cause, and the conviction is conclusive in these proceedings. Where dishonesty is integral to the offence, striking off is the presumptive sanction unless truly exceptional facts exist, following Law Society of Singapore v Chia Choon Yang [2018] 5 SLR 1068. Forgery with intent to commit fraud is dishonest, and so is knowingly giving false evidence in his admission affidavit.

Timing. The date of the offences is irrelevant under s 83(2)(a); what matters is the date of conviction, which came after admission. Nothing in ss 94A(1) and 98(1) prevents their use in such a case.

Section 16(4). The false admission affidavit could have engaged s 16(4), as the false statement was substantial. But the court found it neither necessary nor appropriate to proceed under that provision: the application was properly brought under ss 94A(1) and 98(1), and s 16(4) is typically aimed at cases where rehabilitation is the focus, whereas here the conviction revealed a serious character defect that put protection of the public first.

No exceptional circumstances. There was no evidence that his major depressive disorder caused the false statement, and the absence of monetary gain was irrelevant given the harm to the administration of justice. He had breached the trust placed in him as an investigating officer and had fraudulently secured admission to the Bar. Personal mitigation carries little weight in disciplinary proceedings, whose main purpose is to protect the public.

From the judgment