Public Prosecutor v Teo Chee Seng: Culpable Homicide Sentencing Appeal for Infant's Death by Medicated Oil

In Public Prosecutor v Teo Chee Seng, the Court of Appeal of Singapore heard an appeal by the Public Prosecutor against the sentence imposed on Teo Chee Seng for culpable homicide not amounting to murder. Teo had caused the death of an infant by feeding her medicated oil. The trial judge sentenced Teo to four years' imprisonment, taking into account an additional charge of fabricating false evidence. The Court of Appeal allowed the appeal, finding the sentence manifestly inadequate and substituting it with a sentence of seven years.

1. Case Overview

1.1 Court

Court of Appeal

1.2 Outcome

Appeal allowed.

1.3 Case Type

Criminal

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

The Public Prosecutor appealed against the four-year sentence for Teo Chee Seng, who caused an infant's death by feeding her medicated oil. The Court of Appeal allowed the appeal, finding the sentence manifestly inadequate.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Public ProsecutorAppellantGovernment AgencyAppeal allowedWon
Jason Chan of Deputy Public Prosecutors
Cheng Howe Ming of Deputy Public Prosecutors
Woo Kar Wai of Deputy Public Prosecutors
Teo Chee SengRespondentIndividualSentence increasedLost

3. Judges

Judge NameTitleDelivered Judgment
Tan Lee MengJudgeYes
Chao Hick TinJustice of the Court of AppealNo
Yong Pung HowChief JusticeNo

4. Counsels

Counsel NameOrganization
Jason ChanDeputy Public Prosecutors
Cheng Howe MingDeputy Public Prosecutors
Woo Kar WaiDeputy Public Prosecutors
Michael ChiaSankar Ow and Partners

4. Facts

  1. Teo Chee Seng pleaded guilty to culpable homicide for causing the death of a seven-month-old infant.
  2. Teo fed the infant medicated oil on multiple occasions to stop her from crying.
  3. The infant died from acute salicylic acid poisoning.
  4. Teo attempted to fabricate false evidence by asking another person to take responsibility.
  5. The trial judge sentenced Teo to four years' imprisonment.
  6. The Public Prosecutor appealed against the sentence, arguing it was manifestly inadequate.

5. Formal Citations

  1. Public Prosecutor v Teo Chee Seng, Cr App 3/2005, [2005] SGCA 28

6. Timeline

DateEvent
Tragic event occurred when Teo had to look after the infant.
Sentence backdated to this date.
Decision Date

7. Legal Issues

  1. Manifest inadequacy of sentence
    • Outcome: The Court of Appeal found the original sentence manifestly inadequate and increased it.
    • Category: Substantive
    • Related Cases:
      • [2005] 2 SLR 220
      • [1999] 1 SLR 138

8. Remedies Sought

  1. Increased sentence

9. Cause of Actions

  • Culpable Homicide not amounting to murder
  • Fabricating false evidence

10. Practice Areas

  • Criminal Law
  • Appeals

11. Industries

  • No industries specified

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Purwanti Parji v PPCourt of AppealYes[2005] 2 SLR 220SingaporeCited for the principle that the law recognizes the need to protect vulnerable and defenseless persons such as children.
PP v Mok Ping Wuen MauriceHigh CourtYes[1999] 1 SLR 138SingaporeCited for the principle that the effect of taking into consideration other offences is to enhance the sentence that would otherwise be awarded.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Penal Code (Cap 224, 1985 Rev Ed), s 304 (b)Singapore
Penal Code, s 193Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Culpable homicide
  • Medicated oil
  • Manifestly inadequate
  • Vulnerability of deceased
  • Fabricating false evidence
  • Acute salicylic acid poisoning

15.2 Keywords

  • culpable homicide
  • sentencing
  • infant death
  • medicated oil
  • Singapore
  • criminal appeal

17. Areas of Law

Area NameRelevance Score
Sentencing95
Culpable Homicide90
Criminal Law90
Criminal Procedure80
Murder60
Falsification of Documents50
Evidence40

16. Subjects

  • Criminal Law
  • Sentencing