Ler Wee Teang Anthony v PP: Abetment of Murder & Appellate Review of Factual Findings

In Ler Wee Teang Anthony v Public Prosecutor, the Court of Appeal of Singapore heard an appeal by Anthony Ler against his conviction and death sentence for abetting the murder of his wife, Annie Leong Wai Muen. The prosecution argued that Anthony had instigated Z, a minor, to commit the murder. The Court of Appeal dismissed the appeal, finding sufficient evidence to substantiate the charge of abetment of murder beyond a reasonable doubt.

1. Case Overview

1.1 Court

Court of Appeal

1.2 Outcome

Appeal Dismissed

1.3 Case Type

Criminal

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Anthony Ler was convicted of abetting the murder of his wife. The Court of Appeal upheld the conviction, finding sufficient evidence of instigation.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Public ProsecutorRespondentGovernment AgencyAppeal DismissedWon
Jaswant Singh of Deputy Public Prosecutors
Lee Jwee Nguan of Deputy Public Prosecutors
Ler Wee Teang AnthonyAppellantIndividualAppeal DismissedLost

3. Judges

Judge NameTitleDelivered Judgment
Yong Pung HowChief JusticeYes
Chao Hick TinJudge of AppealNo
Tan Lee MengJudgeNo

4. Counsels

Counsel NameOrganization
Jaswant SinghDeputy Public Prosecutors
Lee Jwee NguanDeputy Public Prosecutors
Anand NalachandranHarry Elias Partnership
Subash AnandanHarry Elias Partnership

4. Facts

  1. Anthony and Annie were estranged and divorce proceedings were imminent.
  2. Anthony discussed killing Annie with several people, including Z, Gavin, Tze Howe, Berlinda and Marilyn.
  3. Anthony showed Gavin photos of Annie and knives that could be used to kill her.
  4. Anthony gave Z $100 to buy a knife and other items.
  5. Anthony and Z practiced how to attack Annie.
  6. Z stabbed Annie to death.
  7. Anthony communicated with Z via computer after the murder, discussing the crime.

5. Formal Citations

  1. Ler Wee Teang Anthony v Public Prosecutor, Cr App 27/2001, [2002] SGCA 23

6. Timeline

DateEvent
Abetment of murder occurred between 1 and 14 May 2001
Annie Leong Wai Muen was murdered
Police searched Anthony’s HDB maisonette at Pasir Ris
Z admitted to being the assailant
Date of The New Paper found at crime scene and in Anthony's home
Appeal dismissed

7. Legal Issues

  1. Abetment of Murder
    • Outcome: The court found sufficient evidence to substantiate the charge of abetment of murder beyond a reasonable doubt.
    • Category: Substantive
    • Sub-Issues:
      • Instigation
      • Common intention
  2. Admissibility of Evidence
    • Outcome: The court held that statements by the appellant about getting someone to kill the deceased were relevant.
    • Category: Procedural
    • Sub-Issues:
      • Relevance of statements indicating intention to commit a crime
  3. Appellate Review of Factual Findings
    • Outcome: The court held that an appellate court will not disturb a lower court's findings of fact unless they are clearly wrong and against the weight of the evidence.
    • Category: Procedural
    • Sub-Issues:
      • Standard of review for findings of fact by a trial court
    • Related Cases:
      • [1992] 1 SLR 713

8. Remedies Sought

  1. Appeal against conviction and sentence

9. Cause of Actions

  • Abetment of Murder

10. Practice Areas

  • Criminal Appeals
  • Homicide
  • Abetment

11. Industries

  • No industries specified

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Lim Ah Poh v PPCourt of AppealYes[1992] 1 SLR 713SingaporeCited for the principle that an appellate court will not disturb a lower court's findings of fact unless they are clearly wrong and against the weight of the evidence.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Penal Code (Cap 224) ss 109 & 302Singapore
Evidence Act (Cap 97, 1997 Ed) s 14Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Abetment
  • Instigation
  • Common intention
  • Causation
  • Motive
  • Circumstantial evidence
  • Credibility of witnesses

15.2 Keywords

  • Abetment of murder
  • Criminal law
  • Singapore
  • Court of Appeal
  • Evidence
  • Instigation

17. Areas of Law

Area NameRelevance Score
Criminal Law95
Murder90
Abetment90
Evidence70
Criminal Procedure60
Asset Recovery30

16. Subjects

  • Criminal Law
  • Evidence
  • Appeals