Darren Ang

Torn Fealty to the Courts and Science: Conundrums over Medical Expert Opinions (II/II)

By Agnes Lo, Bryont Chin, Darren Ang, Leon Tay & Louis Lai

The previous section of this article examined the different considerations that affect the weight accorded to expert evidence.1 It was observed that judges scrutinize the expert himself (his qualifications and the level and relevance of his specialization) and also his testimony (its cogency, internal consistency, and consistency with the facts).

A survey of local case law and overseas publications reveals issues surrounding this assessment. These have been directed to the reliability of expert opinions itself, applying generally to all experts. Unfortunately, local jurisprudence has not addressed these concerns.

The lacuna in local jurisprudence on this point is especially unfortunate given the widespread prevalence of and reliance upon medical expert opinion in Singapore. It is thus pertinent to examine these issues and their causes in detail.


A. Partiality and bias of experts

Case law reflects a persistent concern about the partiality and bias of experts but also a recognition that this will persist as long as litigation remains adversarial. Ideally, under Order 40A Rule 2(2) of the Rules of Court2 [ROC], experts should bear an exclusive duty to the Court; however, this is usually not the case in practice. A “market-place” mentality continues to prevail, in which parties select experts because the latter’s views are “already known and, consequently, would advance the party’s case.”3 Both the courts and commentators like Professor Pinsler have acknowledged that the source of this paradigm is the adversarial model, since parties assume that their “remuneration of the expert justifies a measure of loyalty that will somehow manifest to his advantage in the determination of the case before or at trial”.4 Therefore, as long as the adversarial model continues to be adopted, parties will continue to pay, retain, and offer the experts future engagements—all of which incentivise experts to provide opinion evidence slanted in favour of the clients who engage them.5

To make matters worse, breaches of the procedural duty under Order 40A above attract no direct penalties in themselves. There is only an evidential penalty: if an expert is found to be partial, the court completely or partially disregards his testimony.6 This does not seem to have been enough: from the introduction of Order 40A in 2000 to date, the courts have continued to observe bias in experts.7 Therefore, bias among experts remains a real problem in the court today.

B. A fear of testifying in Court

Also flowing from the adversarial model and the process of adjudication itself is medical experts’ intrinsic fear of testifying in court. Experts—and medical experts in particular—tend to steer clear of the witness stand for two reasons: a fear that they may not be sufficiently competent to testify, and a fear that they may be shamed or wronged on the stand.8

While there is no equally comprehensive study, local doctors have expressed the same fears of testifying due to natural embarrassment and a fear of damaging their colleagues’ reputations.9 Failing to address these fears will restrict plaintiffs’ access to medical experts or otherwise make engaging experts more expensive. This reluctance will affect the quality and accessibility of court adjudication, reliant as it is on expert testimony.

C. Insufficiency of factual bases for medical opinions

Experts often have insufficient facts to support their opinion. This is because in litigation, they are likely to be engaged before trials begin since their opinions are critical in establishing the client’s case and thus predict the likelihood of success at trial.10 However, this means that much of the evidence the expert relies upon to develop his report and testimony will be “untested raw material” since this evidence has yet to be tested in court.11 This concern came to a head in Khoo Bee Kiong,12 where the court expressly questioned the factual basis of an expert opinion prepared with affidavits of evidence in chief.

This is likely to be aggravated in medical negligence claims, where the recent Supreme Court Practice Directions13 impose an accelerated case management timeline. As an expert report must now be filed before the claim itself begins, medical experts have less time and evidence to formulate their opinions.


Apart from issues with the expert opinions themselves, there are also notable concerns with the judicial treatment of medical expert opinions reflected in empirical studies. These suggest that there are systemic issues with judges’ competence to assess the reliability and credibility of a medical expert’s opinion. These issues manifest themselves in two main ways: lack of clarity and improper assessment of an expert opinion’s reliability and weight.

A. Lack of clarity

At its core, the court’s assessment of the weight to be given to a medical expert’s opinion is a discretionary exercise. It is naturally opaque and applied circumstantially, and may hence appear uncertain. This means that the other stakeholders involved—lawyers, clients, and the medical experts themselves—may misunderstand the standard expected of them. Jurs, for instance, observes that legal professionals tend to over-estimate the value of personality and credentials, whereas judges place a greater emphasis on partiality and bias, tentativeness, and the technicality of the opinions proffered.14 Clarity in this area is much needed;15 consensus and better articulation of the relevant considerations would assist greatly.

B. Improper assessment of reliability and weight

Beyond a lack of clarity, too great an emphasis may also be placed by judges on considerations unrelated to or insignificant in assessing the weight of opinion evidence. For instance, “impressions of the analyst’s demeanour and credibility, like the ability to survive cross-examination, will not in most cases provide rational means of assessing the probative value of an opinion.”16 The English courts, for example, have been criticised for assessing expert opinion evidence on this basis, which has led to factually unsustainable acquittals.17

Studies suggest that this improper assessment persists because medically-untrained judges and jurors may not be sufficiently competent to assess the value of medical expert opinions. For instance, jurors look for consensus supporting the expert opinion, whether the opinion is applicable in the case at hand,18 and how experts communicate their opinions,19 instead of instead of assessing the true admissibility and reliability of the expert opinion. These indicators do not, however, necessarily go towards the veracity of an opinion.20 Where earlier studies have suggested that that this may be due to a lack of education in the expert’s field,21 it is understandable why some doctors feel that laypersons like jurors “should not decide medical malpractice cases because of the arcane issues involved in the practice of medicine.”22

Local jurisprudence has only engaged these concerns in the abstract. Ronald Wong posits that the law’s insistence on the finality of an opinion for it to be accepted as evidence conflicts with the scientific method, which relies not on finality, but rather social acceptance to establish a theory as valid.23 This mirrors the observation in Levett and Korvera’s review that “individuals often are unable to evaluate statistics or methodology properly… [such that] it is reasonable to assume that jurors may be unsuccessful in independently detecting flaws in research presented by an expert in court.”24 Nonetheless, Wong has argued that it is still preferable for a judge to continue to adjudicate on the issue, and if the expert evidence is insufficiently reliable, a judge ought to make his findings of fact on the burden of proof.25 Wong’s argument—defended on grounds of a public interest in resolving disputes—contrasts with Professor Hor’s view that judges lack any institutional capacity to determine the veracity of expert opinion. 26

While the argument that professional judges ought to continue to adjudicate on expert opinions resounds with a strong motivation to do so, the question of institutional competence will inevitably haunt the ability of a judge to assess an expert’s opinion. This is especially the case if adjudication leads to reliance on wrong or inaccurate expert opinions as expressed in the studies above.


Concerns over unreliable expert opinions have been the subject of statutory reform. The government has astutely implemented a certification regime for opinion evidence for psychiatrists in criminal cases under s 270 of the Criminal Procedure Code27 [CPC] which has recently come into force this year. The amendments provide that that only certified psychiatrists can testify. This places the control over the admission and use of psychiatrists’ opinions in the hands of a Selection Committee instituted for these purposes.

In other aspects, however, reform continues to be lacking. The independence of experts continues to be secured by weak duties under s 269 CPC which do not depart from the phraseology of Order 40A ROC. The amendments to the CPC do not address the deeper concerns relating to adversarial litigation or pronounce on the feasibility of alternatives such as independent experts or assessors.

Therefore, the fundamental question remains as to whether the amendments will indeed improve the reliability of psychiatric evidence and be a viable option across other classes of medical experts as well; or, alternatively, whether it would entrench a preferred doctrine of psychiatric testimony.28 Psychiatrists have questioned why they were the only class of expert that required supervision, while the Criminal Bar expressed that it would be preferable if the selection process also included defence counsel as a member of the Selection Committee.29 If the latter is the case, then the amendments contribute to the issues of bias instead of resolving them.

Beyond partiality concerns, other issues raised above have yet to be verified and recognized. While the concern that experts may not have sufficient factual evidence to support their opinions has been expressed judicially, the expediting of court procedure is unhelpful in this respect. Issues that judges may lack the institutional capacity to assess medical expert opinions, or that they may demand a different standard from the general public, have not been validated in Singapore. While there are extra-legal methods employed to cope with these such as a training course for medical experts, the impact of these courses has not yet been observed.


The discussion above has traced a number of difficulties in the use of medical experts’ opinions, as well as the use of experts in general. The judicial approach to assessing the probative value and reliability of opinions is plagued with difficulties stemming from intractable concerns that medical experts tend to be partial towards the party that hired them, and that they often lack sufficient facts to properly develop an opinion. Although there are both existing procedural laws and extraneous support to safeguard the reliability of medical expert opinions, these are often watered down by parties’ adversarial mentalities. Where there is little incentive to cooperate, parties do not actively rely on the same measures such as concurrent expert evidence or discussion. Other issues, such as fear among medical professionals of proffering testimony against their fellow doctors, or the competence of the Court to adjudicate on the same, have hardly been the subject of discussion by the legal community in Singapore.

This is unfortunate as expert opinions are the lifeblood of many disputes. Even before the case commences, expert opinions are important in managing client expectations, where the expert’s assessment indicates the client’s likelihood of success.30 Medical experts are of special significance in the field given that they are relevant in many legal disputes and, in fact, comprise the bulk of experts sought.

Meeting the concerns above would require lawyers, courts, and medical experts alike to come to a clear consensus on their roles and competencies in adjudication. Coping with the difficulties of an adversarial model will also require a change in mindset and culture: lawyers and courts must emphasise to medical experts that in testifying, they are helping society as a whole. In this regard, the authors posit that empirical studies will be helpful in assessing the gravity of each issue, and the effectiveness of measures to cope with them.

*The authors are a group of undergraduate students in the National University of Singapore, and are presently in the course of an empirical research project on the subject.

[1] See Agnes Lo, Bryont Chin, Leon Tay & Louis Lai, “Torn Fealty to the Courts and Science: Conundrums over Medical Expert Opinions (I/II)”, online: Juris Illuminae, Vol 10 <http://www.singaporelawreview.com/juris-illuminae-entries/2018/torn-fealty-to-the-courts-and-science-conundrums-over-medical-expert-opinions-i>.

[2] Cap 322, R 5, 2014 Rev Ed Sing.

[3] Jeffrey Pinsler, “Expert Evidence and Adversarial Compromise: A reconsideration of the Expert’s Role and Proposals for Reform” [2015] 27 Sing Ac LJ 55 at [2].

[4] Ibid at [15].

[5] Vita Health Laboratories Pte Ltd v Pang Seng Meng [2004] 4 SLR 162, at [81].

[6] If the expert attempts or is seen to be an advocate for his party’s cause, he will inexorably lose credibility: per VK Rajah JA in Vita Health Laboratories Pte Ltd v Pang Seng Meng [2004] 4 SLR 162 at [83].

[7] Supra note 3 at [4].

[8] See e.g. “Medical Malpractice - Expert Testimony” (1965-1966) 60 Nw UL Rev 834.

[9] See Joseph Sheares, “Writing the Expert Report and Testifying in Court (Part 2)”, SMA News (February 2015), online: https://www.sma.org.sg/UploadedImg/files/Publications%20-%20SMA%20News/4702/Professionalism.pdf at 23.

[10] Amanda Stevens, “Editorial: Reliability and cogency of expert witness evidence in modern civil litigation” (2011) 66 Anaesthesia 764.

[11] Khoo Bee Keong v Ang Chun Hong [2005] SGHC 128 at [72].

[12] Ibid.

[13] See Sing, The Supreme Court Practice Directions (2017) part XXIII, s 158(1), referring to Appendix J (High Court Protocol for Medical Negligence Cases), online: <https://epd.supremecourt.gov.sg/downloads/Appendix_J/APPENDIX_J.pdf> at 4.1-4.2.

[14] Ibid.

[15] See e.g. the Ministry’s comments in proposing amendments to s 270 of the CPC, which it expressed to be for the purposes of ensuring that evidence given by psychiatrists is “competently arrived at and objective”: Siau Ming En, “Proposed psychiatric panel must be large enough for smoother defence: Lawyers”, Today (28 July 2017), online: <https://www.todayonline.com/singapore/proposed-psychiatric-panel-must-be-large-enough-smoother-defence-lawyers>.

[16] Gary Etmond, “Legal versus non-legal approaches to forensic science evidence” (2016) 20:1 IJEP 3 at 24.

[17] Ibid.

[18] Lora M Levett & Margaret Bull Korvera, “The Effectiveness of Opposing Expert Witnesses for Educating Jurors about Unreliable Expert Evidence” (2008) 32:4 Law and Human Behaviour 363-374, at 364.

[19] Andrew W Jurs, “Expert Prevalence, Persuasion, and Price: What Trial Participants Really Think About Experts” (2016) 91 Ind LJ 353.

[20] Kovera MB, McAuliff BD & Hebert KS, “Reasoning about Scientific Evidence: Effects of Juror Gender and Evidence Quality on Juror Decisions in a Hostile Work Environment case” (1999) 84:3 J Appl Psychol 362 at 365.

[21] See e.g. Kalven, Harry Jr & Hans Zeisel, The American Jury (Chicago: University of Chicago Press, 1966) at 153; cited in Sanja Kutnjak Ivkovic & Valerie P Hans, “Jurors’ Evaluations of Expert Testimony: Judging the Messenger and the Message” (Cornell Law Faculty Publications, Paper 385, 2003) at 443.

[22] Neil Vidmar, “Lay Decision-Makers in the Legal Process” in Peter Cane & Herbert M Kritzer, The Oxford Handbook of Empirical Legal Research (OUP, 2010) 626, at 633.

[23] Ronald JJ Wong, “Judging between Conflicting Expert Evidence” (2014) 26 Sing Ac LJ 169.

[24] Supra note 18.

[25] Supra note 23.

[26] Ibid, citing Michael Hor, “When Experts Disagree” (2000) Sing JLS 241 at 243.

[27] Cap 68, 2012 Rev Ed Sing.

[28]Supra note 15.

[29] Ibid.

[30] Supra note 10.

The PDF version of this article is available for download here.

Footpath Warriors: A Proposed Sentencing Framework for Personal Mobility Device Accidents

By Darren Ang*


The use of personal mobility devices [PMDs] on footpaths in Singapore has led to numerous PMD-related accidents,1 some of which have resulted in grave injuries to the victims.2 The propensity for PMDs to cause harm is well known by the public – there have been numerous calls to tighten legislative controls on PMD usage, including a request to completely ban PMD usage on footpaths.3

These calls have not gone unanswered, and Parliament has been consistently tightening legislative controls over PMD usage over the past year. The passing of the Active Mobility Act 20174 [AMA] added s 5A to the Road Traffic Act5, which expressly prohibits the use of PMDs on public roads in most circumstances. Following the AMA, the Active Mobility Regulations 20186 introduced additional controls over, inter alia, the sale and modification of PMDs.

While these legislative controls are relatively new, and their effectiveness cannot be conclusively determined, it unfortunately appears that the measures in place are still insufficient – calls for the complete banning of PMDs have not ceased.7 To supplement the legislative measures already in place, the courts may step in to pass sentence on PMD users who cause hurt to pedestrians, and in doing so, deter such careless behaviour enough to lower the incidence of PMD accidents.


This article proposes a sentencing framework for PMD accident cases where grievous hurt is caused, by reconciling the unique characteristics of PMD accident cases with the sentencing framework for causing grievous hurt by a negligent act that endangers human life under s 338(b) of the Penal Code8 [PC] in Tang Ling Lee v Public Prosecutor9 [Tang Ling Lee]. The offence of causing grievous hurt by a negligent act that endangers human life is chosen as a benchmark, as most reported PMD accidents would likely fall under this provision.10


In Tang Ling Lee, See Kee Oon J laid down a general sentencing framework to be applied for road traffic cases charged under s 338(b) of the PC when the accused claims trial (referred to in this article as the ‘Tang Ling Lee framework’).11 The Tang Ling Lee framework is a two-step inquiry, which first categorises the offence under one of three pre-established categories to determine a starting point sentence (referred to in this article as the ‘three-category approach’). Following which, the framework allows further adjustments to be made to take into account the relevant mitigating and aggravating factors (referred to in this article as the ‘adjustments step’).12

At the first step of the inquiry, a presumptive sentencing range will be determined as a starting-point sentence, having regard to the twin considerations of harm and culpability.13 See Kee Oon J summarised the three-category approach in the following table format:14

  • Category 1:

    • Circumstances: Lesser harm and lower culpability;

    • Presumptive Sentencing Range: Fines.

  • Category 2:

    • Circumstances: Greater harm and lower culpability Or Lesser harm and higher culpability;

    • Presumptive Sentencing Range: One to two weeks’ imprisonment.

  • Category 3:

    • Circumstances: Greater harm and higher culpability;

    • Presumptive Sentencing Range: More than two weeks’ imprisonment.

See Kee Oon J defined “harm” as the “nature and degree of the grievous bodily injury caused to the victim(s)”15, and the “degree of culpability” as “the degree of relative blameworthiness disclosed by an offender’s actions … measured chiefly in relation to the extent and manner of the offender’s involvement in the criminal act”.16 Additionally, the factors which would affect the “culpability” limb under the three-category approach would include: (i) the manner of driving, (ii) the circumstances which might have increased the danger to road users, and (iii) the offender’s reasons for driving.17


While the Tang Ling Lee framework was caveated to only apply to road traffic cases,18 it has been adjusted to apply in non-road traffic cases as well. Most notably, the District Judge in Public Prosecutor v Cai Mei Ying19 [Cai Mei Ying] applied the three-category approach under the Tang Ling Lee framework for a s 338(b) case involving a bicycle accident, but held that the presumptive sentencing ranges were not binding due to the different contexts in which the cases occurred.20

It is submitted that when a PMD accident case charged under s 338(b) of the PC reaches the courts, there would be no practical reason to deviate from the approach taken by the District Judge in Cai Mei Ying. Moreover, the District Judge in Cai Mei Ying noted that the Tang Ling Lee framework was expressly caveated to only apply to road traffic cases, but recognised that the parties had agreed that “because Tang Ling Lee involves the co-existence of vehicles and humans in shared spaces”, the framework was applicable to their case.21 PMD accidents also involve the “co-existence of vehicles and humans in shared spaces”, and it would follow that the approach taken in a future case involving a PMD accident is likely to be similar to the approach taken by the District Judge in Cai Mei Ying.

It would then be apposite to consider what adjustments might be made to the Tang Ling Lee framework for PMD accident cases, and it is argued that the main considerations for adjusting the Tang Ling Lee framework in these cases would be: (i) the lower propensity for PMDs to cause harm when compared to motor vehicles (referred to in this article as the ‘harm factor’), and (ii) the objective of general deterrence (referred to in this article as the ‘deterrence factor’). If the courts were to follow the approach in Cai Mei Ying for adjusting the Tang Ling Lee framework, they would apply the three-category approach without using the presumptive sentencing ranges, and then account for the above two considerations at the adjustments step of the Tang Ling Lee framework. These two considerations will now be dealt with in turn.

A. Downward adjustments for the ‘harm factor’

PMDs have a lower propensity to cause harm than motor vehicles, as they travel at lower speeds and are not as heavy as motor vehicles. This could warrant a downward adjustment of the starting-point sentence at the adjustments step of the Tang Ling Lee framework.

As discussed above, the approach in Cai Mei Ying ought to be the first port-of-call for the discussion. However, the District Judge in Cai Mei Ying did not make a clear finding on the effect of the ‘harm factor’, though it was noted that as a guiding principle, “drivers of heavy vehicles stand to receive heavier punishments than riders of light vehicles due to the greater damage their vehicles can cause”.22

It is then helpful to consider the approach taken in Public Prosecutor v Khairul bin Hairuman23 [Khairul], which was a case involving a fatal bicycle accident. The accused in Khairul was charged under the rashness limb of s 304A of the PC, and the District Judge applied the three-category approach from the case of Public Prosecutor v Ganesan Sivasankar24 [Ganesan], including the presumptive sentencing ranges.

The Ganesan framework was also laid down by See Kee Oon J to apply to any s 304A rashness case when the accused claims trial, and it uses a three-category approach followed by an adjustments stage as with the Tang Ling Lee framework.25 The only differences between the two frameworks are that the Ganesan framework does not consider the harm caused (as it is, by definition of the offence, the death of the victim),26 and that the presumptive sentencing ranges in Ganesan under the three-category approach are more severe. The table laid out by See Kee Oon J in Ganesan is illustrative of these differences:27

  • Category 1:

    • Accused’s culpability: Low;

    • Presumptive sentencing range: 3 to 5 months’ imprisonment.

  • Category 2:

    • Accused’s culpability: Moderate;

    • Presumptive sentencing range: 6 to 12 months’ imprisonment.

  • Category 3:

    • Accused’s culpability: High;

    • Presumptive sentencing range: More than 12 months’ imprisonment.

The District Judge in Khairul found that the accused’s conduct fell within Category 2 of the Ganesan framework, and then discounted the accused’s sentence at the adjustments stage to “reflect the lower consciousness of risk of harm towards others associated with the riding of the bicycle in comparison with the riding or driving of motorised vehicles”.28

The approach in Khairul would support the position that the lower propensity for PMDs to cause harm could count for a significant downward adjustment at the adjustments stage of the Tang Ling Lee framework.

B. Upward adjustments for the ‘deterrence factor’

As discussed in the introduction of this article, PMD usage is an issue of great public concern in Singapore, and deterrent sentencing in the courts would be an appropriate supplement for the legislative controls already in place. Therefore, the court may be inclined to make an upward adjustment of the starting-point sentence for the purpose of general deterrence.

In Cai Mei Ying, the ‘deterrence factor’ was effectively the only aggravating factor taken into consideration at the adjustments stage of the Tang Ling Lee framework.29 Interestingly, the District Judge was cognisant of the issue of PMD accidents, classifying both cyclists and PMD users within the same class of persons and commenting that “with the increased popularity of PMDs and the use of bicycles … all cyclists and users of PMDs must be reminded to take extra care when they are in shared spaces”.30 Therefore, it is likely that the court would take the ‘deterrence factor’ as a significant aggravating factor at the adjustments stage of the Tang Ling Lee framework.

Additionally, a common thread that binds most cases charged under s 338(b) of the PC is that the accused person had breached certain safety regulations which led to the accident – the accused in Cai Mei Ying was cycling in a no-cycling zone31 and the accused in Tang Ling Lee failed to give way to a motorist with the right of way32. The breach of safety regulations counted towards a finding of higher culpability at the three-category approach stage, ultimately leading to a higher starting-point sentence. Therefore, it could be argued that the purpose of general deterrence is served indirectly at the “culpability” limb of the three-category approach.


To summarise the proposed method for adjusting the Tang Ling Lee framework for PMD accident cases charged under s 338(b) of the PC, the courts are likely to apply the three-category approach without using the presumptive sentencing ranges to determine a starting-point sentence. Following which, at the adjustments stage, the court would account for the ‘harm factor’ to adjust the starting-point sentence downwards and the ‘deterrence factor’ to adjust the starting-point sentence upwards.

For PMD users, who would bear the full brunt of this proposed method, the message is clear – if ever placed in an unfortunate s 338(b) situation where the harm has already been caused, it would be in their best interest to render as much assistance to the victim as necessary and comply with all orders, for a possible finding of lower culpability.

* A most heartfelt thanks to Professor Alan Tan, for answering my queries and helping immensely with the framing of my research questions.

[1] Adrian Lim, “Parliament: About three accidents a week involving personal mobility device users” (8 January 2018), The Straits Times, online: <www.straitstimes.com/politics/parliament-average-of-three-accidents-a-month-involving-pedestrians-and-personal-mobility>.

[2] Shaffiq Idris Alkhatib, “Teen e-scooter rider pleads guilty in incident which caused pedestrian severe brain injuries” (13 June 2018), The Straits Times, online: <www.straitstimes.com/singapore/courts-crime/teen-e-scooter-rider-pleads-guilty-in-incident-which-caused-pedestrian-severe>.

[3] Desmond Ng & Kan Lau, “Why being hit by an e-scooter can be deadly – and a call to ban them from footpaths” (20 May 2018), Channel NewsAsia, online: <www.channelnewsasia.com/news/cnainsider/e-scooter-ban-footpaths-accidents-safety-registration-debate-10250946>.

[4] No 3 of 2017, Sing.

[5] Cap 276, 2004 Rev Ed Sing.

[6] S 251/2018 Sing.

[7] Rodney Tan, “It Is Time to Ban E-Scooter[s] in Singapore” (last updated 11 December 2018), ipetitions, online: <www.ipetitions.com/petition/it-is-time-to-ban-e-scooter-in-singapore>.

[8] Cap 224, 2008 Rev Ed Sing.

[9] [2018] SGHC 18; [2018] 4 SLR 813.

[10] For example, see supra, notes 1-3.

[11] Supra note 9 at [32].

[12] Ibid.

[13] Ibid.

[14] Ibid at [31]. The information is represented in table format in the PDF version of this article.

[15] Ibid at [25].

[16] Ibid.

[17] Ibid at [27].

[18] Ibid at [24].

[19] [2018] SGMC 56.

[20] Ibid at [23].

[21] Ibid at [20].

[22] Ibid at [24].

[23] [2018] SGMC 16.

[24] [2017] SGHC 176; [2017] 5 SLR 681.

[25] Ibid at [54].

[26] Ibid.

[27] Ibid at [55]. The information is represented in table format in the PDF version of this article.

[28] Supra note 23 at [38].

[29] Supra note 19 at [37].

[30] Ibid.

[31] Ibid at [2].

[32] Supra note 9 at [5].

The PDF version of this article is available for download here.