PP v Purwanti Parji: Culpable Homicide & Sentencing in Employer-Domestic Worker Relationship

In Public Prosecutor v Purwanti Parji, the High Court of Singapore sentenced Purwanti Parji, an Indonesian domestic worker, to life imprisonment for culpable homicide under Section 304(a) of the Penal Code. The court, presided over by V K Rajah JC, found that Parji intentionally strangled her employer, Har Chit Heang, and attempted to stage it as a suicide. The court emphasized the need for deterrence in cases involving violence in employer-domestic worker relationships, rejecting a lighter sentence despite Parji's youth and difficult background.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Accused convicted and sentenced to life imprisonment.

1.3 Case Type

Criminal

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Purwanti Parji, an Indonesian domestic worker, was convicted of culpable homicide for killing her employer. The court emphasized deterrence and sentenced her to life imprisonment.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Public ProsecutorProsecutionGovernment AgencyConvictionWon
Jaswant Singh of Deputy Public Prosecutors
Chong Kah Wei of Deputy Public Prosecutors
Abigail Ng of Deputy Public Prosecutors
Purwanti ParjiDefendantIndividualLife ImprisonmentLost

3. Judges

Judge NameTitleDelivered Judgment
V K RajahJudicial CommissionerYes

4. Counsels

Counsel NameOrganization
Jaswant SinghDeputy Public Prosecutors
Chong Kah WeiDeputy Public Prosecutors
Abigail NgDeputy Public Prosecutors
Subhas AnandanHarry Elias Partnership
Mohamed Nasser bin Mohamed IsmailMd Nasser Ismail and Co

4. Facts

  1. The accused, an Indonesian domestic worker, strangled her employer.
  2. The accused attempted to stage the death as a suicide.
  3. The accused had previously been reprimanded by the deceased.
  4. The accused admitted to strangling the deceased.
  5. The accused was 17 years old at the time of the offence.
  6. The deceased sustained injuries consistent with strangulation.

5. Formal Citations

  1. Public Prosecutor v Purwanti Parji, CC 31/2004, [2004] SGHC 224

6. Timeline

DateEvent
Offence committed
Police received a call from the accused
Accused arrested
Autopsy performed
Judgment issued

7. Legal Issues

  1. Culpable Homicide
    • Outcome: The court found the accused guilty of culpable homicide.
    • Category: Substantive
    • Sub-Issues:
      • Premeditation
      • Mitigating factors
  2. Sentencing
    • Outcome: The court sentenced the accused to life imprisonment, emphasizing deterrence.
    • Category: Procedural
    • Sub-Issues:
      • Deterrent sentencing
      • Mitigating factors
      • Youth of offender

8. Remedies Sought

  1. Life Imprisonment

9. Cause of Actions

  • Culpable Homicide

10. Practice Areas

  • Criminal Law
  • Sentencing

11. Industries

  • Domestic Services

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Farida Begam d/o Mohd Artham v PPHigh CourtYes[2001] 4 SLR 610SingaporeCited for the need for deterrence and the importance of public policy in cases of employers mistreating foreign domestic workers.
PP v Tan Kei Loon AllanCourt of AppealYes[1999] 2 SLR 288SingaporeCited regarding caution when sentencing young offenders to life imprisonment.
PP v Chaw Aiang WahHigh CourtYes[2004] SGHC 164SingaporeCited for the principle sentencing considerations of retribution and deterrence.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Section 304(a) Penal Code (Cap 224, 1985 Rev Ed)Singapore
Section 302 of the Penal Code (Cap 224, 1985 Rev Ed)Singapore
Section 213 of the Criminal Procedure Code (Cap 68, 1985 Rev Ed)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Culpable homicide
  • Domestic worker
  • Employer
  • Sentencing
  • Deterrence
  • Premeditation
  • Mitigating factors

15.2 Keywords

  • Culpable homicide
  • Domestic worker
  • Singapore
  • Sentencing
  • Life imprisonment

17. Areas of Law

Area NameRelevance Score
Sentencing95
Culpable Homicide95
Criminal Law90
Criminal Procedure85
Domestic worker abuse60
Murder50

16. Subjects

  • Criminal Law
  • Sentencing
  • Employer-Employee Relationship