Shorvon Simon v Singapore Medical Council: Disciplinary Proceedings & Scope of Costs Under Medical Registration Act
In Shorvon Simon v Singapore Medical Council, the Court of Appeal of Singapore heard an appeal regarding the quantum of costs awarded against Prof. Simon Shorvon following disciplinary proceedings under the Medical Registration Act. The Disciplinary Committee found Shorvon guilty of professional misconduct and ordered him to pay costs. The court allowed the appeal in part, reducing the costs to $175,000, clarifying that costs incurred during the Complaints Committee phase were not recoverable as 'incidental' to the Disciplinary Committee proceedings.
1. Case Overview
1.1 Court
Court of Appeal of the Republic of Singapore1.2 Outcome
Appeal Allowed in Part
1.3 Case Type
Regulatory
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal regarding costs in disciplinary proceedings against Prof. Simon Shorvon. The court reduced the quantum of costs, clarifying the scope of recoverable expenses.
1.7 Decision Date
2. Parties and Outcomes
Party Name | Role | Type | Outcome | Outcome Type | Counsels |
---|---|---|---|---|---|
Shorvon Simon | Appellant | Individual | Appeal allowed in part | Partial | Myint Soe, Daniel Atticus Xu, Jamilah bte Ibrahim |
Singapore Medical Council | Respondent | Statutory Board | Costs reduced on appeal | Lost | Tan Chee Meng, Melanie Ho, Chang Man Phing |
3. Judges
Judge Name | Title | Delivered Judgment |
---|---|---|
V K Rajah | Justice of the Court of Appeal | Yes |
Chao Hick Tin | Judge of Appeal | No |
Yong Pung How | Chief Justice | No |
4. Counsels
Counsel Name | Organization |
---|---|
Myint Soe | MyintSoe and Selvaraj |
Daniel Atticus Xu | MyintSoe and Selvaraj |
Jamilah bte Ibrahim | MyintSoe and Selvaraj |
Tan Chee Meng | Harry Elias Partnership |
Melanie Ho | Harry Elias Partnership |
Chang Man Phing | Harry Elias Partnership |
4. Facts
- Prof Simon Shorvon, a research scientist, was the director of the National Neuroscience Institute.
- Shorvon was the lead Principal Investigator of a research project funded by a $10m grant.
- Concerns were raised about research conducted on patients with Parkinson’s disease.
- The NNI appointed an inquiry panel, which found issues with patient confidentiality and ethics approval.
- The NHG filed a complaint with the SMC based on the panel's findings.
- The Disciplinary Committee found Shorvon guilty of professional misconduct.
- The DC directed Shorvon to pay costs and expenses incidental to the proceedings.
5. Formal Citations
- Shorvon Simon v Singapore Medical Council, CA 48/2005, [2005] SGCA 49
- Singapore Medical Council v Shorvon Simon, , [2005] SGHC 93
6. Timeline
Date | Event |
---|---|
NNI appointed an inquiry panel | |
The NNI Report was issued | |
NHG sent a letter to the SMC | |
NHG preferred a complaint with the SMC against the appellant | |
Judge dismissed both appeals | |
Judgment issued |
7. Legal Issues
- Scope of Disciplinary Committee's power to order costs
- Outcome: The court held that costs incurred at the complaints stage were not incidental to the disciplinary proceedings.
- Category: Procedural
- Sub-Issues:
- Whether costs incurred for work done for proceedings before Complaints Committee incidental to proceedings before Disciplinary Committee
- Principles to be applied in taxation of costs
- Outcome: The court provided guidance on the factors to be considered in the taxation of costs, including complexity, skill, and time expended.
- Category: Procedural
- Sub-Issues:
- Particulars required to be furnished in bill of costs
8. Remedies Sought
- Payment of costs and expenses
9. Cause of Actions
- Professional Misconduct
10. Practice Areas
- Disciplinary Proceedings
- Taxation of Costs
11. Industries
- Healthcare
12. Cited Cases
Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
---|---|---|---|---|---|
Chia Yang Pong v Singapore Medical Council | High Court | Yes | [2004] 3 SLR 151 | Singapore | Cited regarding the limitation of fines imposed by the SMC. |
Tan Hun Hoe v Harte Denis Mathew | High Court | Yes | [2001] 4 SLR 317 | Singapore | Cited as a comparison for costs awarded in medical negligence suits. |
Tan Boon Hai v Lee Ah Fong | High Court | Yes | [2002] 1 SLR 10 | Singapore | Cited as a comparison for costs awarded per day. |
Jeyaretnam Joshua Benjamin v Lee Kuan Yew | N/A | Yes | [1993] 1 SLR 185 | Singapore | Cited regarding the ascertainment of costs allowed for similar cases. |
Lipkin Gorman v Karpnale Ltd | N/A | Yes | [1989] 1 WLR 1340 | N/A | Cited regarding the justification for departure from the norm. |
Tullio v Maoro | N/A | Yes | [1994] 2 SLR 489 | Singapore | Cited regarding the reluctance of an appellate court to interfere with a judge's exercise of discretion. |
Lim Teng Ee Joyce v Singapore Medical Council | N/A | Yes | [2005] 3 SLR 709 | Singapore | Cited regarding the application of usual principles to the assessment of costs incurred in a disciplinary process. |
Re Fahy’s Will Trusts | N/A | Yes | [1962] 1 WLR 17 | N/A | Cited for the interpretation of the words 'and incidental to' in an order for costs. |
13. Applicable Rules
Rule Name |
---|
Rules of Court (Cap 322, R 5, 2004 Rev Ed) |
14. Applicable Statutes
Statute Name | Jurisdiction |
---|---|
Medical Registration Act (Cap 174, 2004 Rev Ed) | Singapore |
Medical Registration Act (Cap 174, 2004 Rev Ed) | Singapore |
Medical Registration Act (Cap 174, 2004 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Disciplinary Committee
- Medical Registration Act
- Taxation of Costs
- Complaints Committee
- Professional Misconduct
- Getting-up Costs
- Incidental Costs
15.2 Keywords
- Medical Council
- Disciplinary Proceedings
- Costs
- Medical Registration Act
- Singapore
- Professional Misconduct
16. Subjects
- Administrative Law
- Civil Procedure
- Medical Law
- Costs
- Disciplinary Proceedings
17. Areas of Law
- Administrative Law
- Civil Procedure
- Medical Law
- Regulatory Law