Attorney-General v Ng Kai Hoe Raymond and another

In HC/OA 988/2025, the Attorney-General applied under the Supreme Court of Judicature Act 1969 for orders against Ng Kai Hoe Raymond and Iris Koh Hsiao Pei, a married couple acting as self-represented litigants. The primary order sought against each was a vexatious litigant order under s 74, requiring the High Court's permission to start or continue civil proceedings; the alternative was a general civil restraint order under s 73D, the first such application to come before the court.

The Attorney-General relied on a judicial review against the Health Sciences Authority over COVID-19 vaccine advertising, struck out as disclosing no reasonable cause of action and an abuse of process; a defamation claim against Calvin Cheng, in which Mr Ng's claim was struck out and the claimants' injunction application dismissed; a claim against NUS and an unnamed colleague over an article by one of its academics, struck out with indemnity costs after several failed applications; and Mr Ng's defamation claim against Wong Peng Kong, in which he obtained default judgment but only $1 in nominal damages, the deputy registrar saying it should never have been commenced. The Attorney-General estimated the pair had filed 37 actions from May 2021 to January 2026, and pointed to their public statements, letters of demand, crowdfunding and a litigation sponsorship scheme. Both respondents denied being vexatious and argued the orders would be disproportionate.

1. Whether Mr Ng had habitually and persistently, and without any reasonable ground, instituted vexatious legal proceedings under s 74(1).
2. Whether the same was shown against Ms Koh, assessed on her own conduct.
3. Whether Ms Koh had persisted in bringing actions or applications totally without merit such that an extended civil restraint order would not be sufficient, justifying a general civil restraint order under s 73D.

Applying Lai Swee Lin Linda v Attorney-General [2016] 5 SLR 476, the court found that Mr Ng had brought four actions and seven applications without any reasonable ground, judged by the reasoning of the courts that dealt with them, including an oral stay application made mid-hearing. Default judgment against Mr Wong did not show merit, given the deputy registrar's observations. The proceedings were vexatious because they were obviously untenable. The court added that it appeared they were also pursued for collateral purposes, citing his description of litigation as income, his paid litigation platform and sponsorship scheme, and a template letter of demand seeking $50,000 while offering to settle for $5,000. Habitual and persistent conduct was shown by repeated attempts to relitigate decided points and a widening circle of defendants drawn in through association, such as after his failed claim over the Rice Media article. Self-representation did not excuse conscious decisions by experienced litigants.

For Ms Koh, only her own proceedings counted. Two actions and seven applications lacked reasonable grounds and were vexatious, and her publicity around the judicial review suggested an intent to annoy the authority, so persistence was shown. But habituality was not: her other defamation suits were ongoing, her claim against Mr Cheng survived, and the NUS action alone did not form a pattern.

Under s 73D, at least two actions or applications totally without merit are needed. Ms Koh's were, and given what the court called a blunderbuss approach against an indeterminate range of parties, an order limited to particular subject matter would not suffice. The orders qualify rather than remove access to justice.

The High Court allowed the application, granting the vexatious litigant order against Mr Ng, so that he may not institute or continue civil proceedings in any court without the High Court's permission. Against Ms Koh it refused the vexatious litigant order but granted the alternative general civil restraint order for two years, restraining her from starting new civil actions or applications without permission while leaving her ongoing cases unaffected. No order was made as to costs.