Tang Keng Boon v Public Prosecutor: Corruption - Payments for Police Tip-Offs

In Tang Keng Boon v Public Prosecutor, the High Court of Singapore heard an appeal against Tang Keng Boon's conviction on two charges under the Prevention of Corruption Act. The charges related to payments made to obtain tip-offs on impending police raids on his shop. The High Court, with Yong Pung How CJ presiding, upheld the conviction on the first charge but set aside the conviction on the second charge due to insufficient evidence regarding the appellant's direct involvement in the initial payment. The court found sufficient evidence to support the first charge, concluding that the payments were intended to corruptly influence police officers.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Appeal on the first charge dismissed; appeal against conviction on the second charge allowed.

1.3 Case Type

Criminal

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Tang Keng Boon was convicted of corruption for paying for tip-offs on police raids. The High Court upheld one charge but set aside another due to insufficient evidence.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Public ProsecutorRespondentGovernment AgencyAppeal on the first charge dismissed; appeal against conviction on the second charge allowed.Partial
Low Cheong Yeow of Deputy Public Prosecutor
Tang Keng BoonAppellantIndividualAppeal on the first charge dismissed; appeal against conviction on the second charge allowed.Partial

3. Judges

Judge NameTitleDelivered Judgment
Yong Pung HowChief JusticeYes

4. Counsels

Counsel NameOrganization
Low Cheong YeowDeputy Public Prosecutor
Christina GohChristina Goh & Co

4. Facts

  1. Tang Keng Boon had a 50% share in a business selling original and pirated computer software.
  2. The business was frequently raided by the police due to the nature of selling pirated software.
  3. Tang Keng Boon was informed that Tan Chee Yak (PW4) could prevent such raids for a monthly fee.
  4. Payments were made from the business profits and recorded as 'info' in the accounts.
  5. Tan Chee Yak (PW4) received money on less than ten occasions and regularly between May and September 1998.
  6. The appellant elected to give evidence after his defence was called.
  7. The appellant testified that he did not make any payments for tip-offs in 1996 and that any payments in 1998 were only for lookout services.

5. Formal Citations

  1. Tang Keng Boon v Public Prosecutor, MA 220/1999, [2000] SGHC 9

6. Timeline

DateEvent
Payments for tip-offs allegedly started.
Alice Tan Lay Lian (PW3) was employed in the business.
Payments reduced to $6,000 a month.
Alleged corrupt act occurred in September 1998.
Tang Lee Leng (PW2) made a statement to the CPIB.
Tan Chee Yak (PW4) made a statement to the CPIB.
Tan Chee Yak (PW4) made another statement to the CPIB.
Case Number: MA 220/1999
Decision Date

7. Legal Issues

  1. Corruption
    • Outcome: The court found the appellant guilty of corruptly giving gratification in one instance but not in another.
    • Category: Substantive
    • Sub-Issues:
      • Corruptly giving gratification
  2. Admissibility of Prior Inconsistent Statements
    • Outcome: The court considered the reliability of prior inconsistent statements in assessing a witness's credibility.
    • Category: Procedural
    • Sub-Issues:
      • Impeaching witnesses’ credibility
      • Reliability and accuracy of prior statements

8. Remedies Sought

  1. Appeal against conviction

9. Cause of Actions

  • Corruption

10. Practice Areas

  • Criminal Litigation

11. Industries

  • Technology

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
PP v Ong Teck HuatUnknownYes[1993] 2 SLR 645SingaporeCited to support the conclusion that the tip-offs would have been improper, in breach of police confidentiality and of the police officers' position of trust and responsibility.
Kannan s/o Kunjiraman & Anor v PPUnknownYes[1995] 3 SLR 757SingaporeCited to support the conclusion that it was no answer that PW4 and Allen never intended to pass the money on to police officers and that the whole scheme was said to be a fraud on the appellant.
PP v Khoo Yong HakUnknownYes[1995] 2 SLR 283SingaporeCited for the test to determine if the appellant's conviction on the first charge was proper.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Prevention of Corruption Act (Cap 241)Singapore
s 5(b)(i) of the Prevention of Corruption Act (Cap 241)Singapore
s 147(6) Evidence Act (Cap 97)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Corruption
  • Gratification
  • Tip-offs
  • Police raids
  • Prior inconsistent statements
  • Impeaching witnesses
  • Lookout services

15.2 Keywords

  • Corruption
  • Singapore
  • Criminal Law
  • Evidence
  • Police
  • Tip-offs

17. Areas of Law

Area NameRelevance Score
Prevention of Corruption Act95
Criminal Law90
Offences70
Evidence60
Evidence Law60
Reliability and accuracy of prior statements50
Witnesses50
Impeaching witnesses’ credibility50
Prior inconsistent statements50

16. Subjects

  • Criminal Law
  • Corruption
  • Evidence