Lee Eng Hock v Public Prosecutor: Criminal Revision, Plea of Guilt, and Exercise of Revisionary Power
Lee Eng Hock petitioned the High Court of Singapore for a criminal revision after pleading guilty in the District Court to charges under the Road Traffic Act and the Motor Vehicles (Third Party Risks and Compensation) Act. He was convicted and sentenced to imprisonment and disqualification from driving. Lee Eng Hock claimed he misunderstood his lawyer's advice and pleaded guilty to expedite the matter. Yong Pung How CJ dismissed the petition, finding no irregularity or serious injustice in the plea of guilt.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Petition dismissed
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Criminal revision case where Lee Eng Hock pleaded guilty to charges under the Road Traffic Act and Motor Vehicles Act. The High Court dismissed the petition, finding no serious injustice.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Public Prosecutor | Respondent | Government Agency | Petition dismissed | Won | Janet Wang of Deputy Public Prosecutor |
| Lee Eng Hock | Petitioner | Individual | Petition dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Yong Pung How | Chief Justice | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Janet Wang | Deputy Public Prosecutor |
| Liow Wang Wu, Joseph | Straits Law Practice LLC |
4. Facts
- The petitioner pleaded guilty to driving while disqualified.
- The petitioner pleaded guilty to using a motor lorry without insurance.
- The petitioner claimed he misunderstood his lawyer's advice.
- The petitioner claimed he pleaded guilty to quickly dispose of the matter.
- The petitioner had previously been convicted under s 42A of the Road Traffic Act.
- The petitioner was disqualified from driving from 27 May 2000 to 6 April 2001.
- The petitioner rented a lorry on 1 December 2000.
5. Formal Citations
- Lee Eng Hock v Public Prosecutor, Cr Rev 1/2002, [2002] SGHC 20
6. Timeline
| Date | Event |
|---|---|
| Petitioner disqualified from driving all classes of vehicles | |
| Petitioner drove a motor lorry while disqualified and without insurance | |
| High Court dismissed the petition for criminal revision |
7. Legal Issues
- Criminal Revision
- Outcome: The court found no reason to exercise its revisionary power.
- Category: Procedural
- Sub-Issues:
- Exercise of revisionary jurisdiction
- Requirement of serious injustice
- Plea of Guilt
- Outcome: The court found no irregularity relating to the plea of guilt which caused serious injustice.
- Category: Substantive
- Sub-Issues:
- Understanding the nature and consequences of plea
- Intention to admit without qualification
8. Remedies Sought
- Criminal Revision
9. Cause of Actions
- Violation of s 43(4) of the Road Traffic Act
- Violation of s 3(1) of the Motor Vehicles (Third Party Risks and Compensation) Act
10. Practice Areas
- Criminal Revision
- Traffic Violations
- Plea Bargaining
11. Industries
- Transportation
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Teo Hee Heng v PP | Unknown | Yes | [2000] 3 SLR 168 | Singapore | Cited for the principle that criminal revision is not a 'backdoor appeal' against conviction for accused persons who had pleaded guilty. |
| Ang Poh Chuan v PP | Unknown | Yes | [1996] 1 SLR 326 | Singapore | Cited for the requirement of 'serious injustice' to attract the exercise of the revisionary jurisdiction. |
| Glenn Knight Jeyasingam v PP | Unknown | Yes | [1999] 3 SLR 362 | Singapore | Cited to clarify the relationship between Criminal Procedure Code s 266(1) and the requirement of 'serious injustice'. |
| Mok Swee Kok v PP | Unknown | Yes | [1994] 3 SLR 140 | Singapore | Cited for the principle that the High Court should exercise its revisionary powers only where it is manifestly plain that the offence charged is nowhere disclosed in the statement of facts tendered. |
| Ganesun s/o Kannan v Public Prosecutor | Unknown | Yes | [1996] 3 SLR 560 | Singapore | Cited for the safeguards that should be observed to determine the validity of a plea of guilty. |
| Chua Qwee Teck v PP | Unknown | Yes | [1991] SLR 857 | Singapore | Cited for the principle that an accused's desire to have the matter quickly disposed of does not constitute pressure to plead guilty. |
| R v Peace | Unknown | Yes | [1976] Crim LR 119 | Unknown | Cited for the principle that strong advice from counsel indicating the prospect of being found guilty does not mean the plea was forced on the defendant. |
| R v Turner | Unknown | No | [1970] 2 QB 321 | Unknown | Cited as an exception where the advice is conveyed as the advice of someone who has seen the judge, and has given the impression that he is repeating the judge’s views in the matter. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Road Traffic Act (Cap 276) s 43(4) | Singapore |
| Motor Vehicles (Third Party Risks and Compensation) Act (Cap 189) s 3(1) | Singapore |
| Supreme Court of Judicature Act (Cap 322) s 23 | Singapore |
| Criminal Procedure Code (Cap 68) s 180(1)(b) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Criminal revision
- Plea of guilt
- Revisionary jurisdiction
- Serious injustice
- Disqualification from driving
- Third-party risks insurance
15.2 Keywords
- Criminal revision
- Plea of guilt
- Road Traffic Act
- Motor Vehicles Act
- Driving disqualification
- Third-party risks insurance
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Road Traffic Act | 90 |
| Criminal Revision | 90 |
| Criminal Procedure | 75 |
| Automobile Accidents | 60 |
| Personal Injury | 30 |
| Pleadings | 25 |
| Civil Procedure | 20 |
| Administrative Law | 20 |
16. Subjects
- Criminal Law
- Traffic Law
- Insurance Law
- Criminal Procedure