Purwanti Parji v PP: Life Imprisonment for Culpable Homicide of Elderly Victim by Domestic Worker
Purwanti Parji, an Indonesian domestic worker, was convicted of culpable homicide not amounting to murder for the death of Har Chit Heang. The High Court sentenced Parji to life imprisonment, and she appealed. The Court of Appeal of Singapore, comprising Yong Pung How CJ, Chao Hick Tin JA, and Kan Ting Chiu J, dismissed the appeal, finding the life sentence appropriate given the premeditation, vulnerability of the victim, and the need to protect the employer-domestic worker relationship.
1. Case Overview
1.1 Court
Court of Appeal of the Republic of Singapore1.2 Outcome
Appeal dismissed.
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Purwanti Parji, a domestic worker, was sentenced to life imprisonment for the culpable homicide of her employer's mother. The court dismissed her appeal.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Public Prosecutor | Respondent | Government Agency | Sentence Affirmed | Won | Bala Reddy of Deputy Public Prosecutors Seah Kim Ming Glenn of Deputy Public Prosecutors |
| Purwanti Parji | Appellant | Individual | Appeal dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Yong Pung How | Chief Justice | Yes |
| Chao Hick Tin | Justice of Appeal | No |
| Kan Ting Chiu | Judge | No |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Bala Reddy | Deputy Public Prosecutors |
| Seah Kim Ming Glenn | Deputy Public Prosecutors |
| Subhas Anandan | Harry Elias Partnership |
| Md Nasser bin Md Ismail | Md Nasser Ismail and Co |
4. Facts
- The appellant, a 17-year-old Indonesian domestic worker, strangled her employer's 57-year-old mother.
- The appellant was angry with the deceased for scolding her earlier in the morning.
- The appellant contemplated killing the deceased while she was asleep.
- The appellant strangled the deceased and staged the scene to look like a suicide.
- The appellant cut her fingernails to remove marks from the deceased's neck.
- The appellant called the police and falsely reported that the deceased had locked herself in the room and was going to hurt herself.
5. Formal Citations
- Purwanti Parji v Public Prosecutor, Cr App 17/2004, [2005] SGCA 9
- , , [2004] SGHC 224
6. Timeline
| Date | Event |
|---|---|
| Deceased found dead in Tai Keng house. | |
| Appellant arrested. | |
| Post-mortem examination performed. | |
| Trial below. | |
| Appeal dismissed. |
7. Legal Issues
- Sentencing for Culpable Homicide
- Outcome: The court upheld the life imprisonment sentence, finding that the aggravating factors outweighed the mitigating factors.
- Category: Substantive
- Sub-Issues:
- Aggravating factors in sentencing
- Mitigating factors in sentencing
- Consideration of young offender status
- Related Cases:
- [1991] SLR 146
- (1968) 52 Cr App R 113
- [1997] 3 SLR 643
- [2001] 4 SLR 516
- [2002] 3 SLR 199
- [1999] 2 SLR 288
- [1999] 2 SLR 523
- [2004] SGHC 120
- [1997] 2 SLR 68
- [1999] 1 SLR 138
- [2004] SGHC 164
- [2002] 4 SLR 412
- [2001] 2 SLR 253
- [1995] 1 SLR 537
- [2003] 2 MLJ 189
- [2004] 4 SLR 622
- [2004] SGHC 244
8. Remedies Sought
- Reduction of sentence
9. Cause of Actions
- Culpable Homicide not amounting to murder
10. Practice Areas
- Criminal Law
- Appeals
11. Industries
- Domestic Services
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Neo Man Lee v PP | Singapore Court of Criminal Appeal | Yes | [1991] SLR 146 | Singapore | Endorsed the Hodgson conditions for imposing a life imprisonment sentence. |
| R v Hodgson | English Court of Appeal | Yes | (1968) 52 Cr App R 113 | England | Established conditions justifying a life imprisonment sentence. |
| Abdul Nasir bin Amer Hamsah v PP | Court of Appeal | Yes | [1997] 3 SLR 643 | Singapore | Defined life imprisonment as imprisonment for the remainder of the prisoner’s natural life. |
| PP v Kwok Teng Soon | lower court | Yes | [2001] 4 SLR 516 | Singapore | Decision affirmed in Kwok Teng Soon v PP (Criminal Appeal No 22 of 2001). |
| PP v Ng Kwok Soon | Singapore High Court | Yes | [2002] 3 SLR 199 | Singapore | Clarified that mental impairment is not the only basis for establishing unstable character. |
| PP v Tan Kei Loon Allan | Court of Appeal | Yes | [1999] 2 SLR 288 | Singapore | Exhorted caution when committing a young offender to life imprisonment. |
| PP v Tan Fook Sum | Court of Appeal | Yes | [1999] 2 SLR 523 | Singapore | Established that premeditation is an aggravating circumstance. |
| PP v Raffi bin Jelan | Singapore High Court | Yes | [2004] SGHC 120 | Singapore | Stated that offenders who commit offences against vulnerable persons ought to be more severely dealt with by the court. |
| Ooi Joo Keong v PP | Court of Appeal | Yes | [1997] 2 SLR 68 | Singapore | Established that prevalence of an offence is a relevant consideration for sentencing. |
| PP v Mok Ping Wuen Maurice | Singapore High Court | Yes | [1999] 1 SLR 138 | Singapore | Rehabilitation is the dominant consideration where the offender is 21 years and below. |
| PP v Chaw Aiang Wah | Singapore High Court | Yes | [2004] SGHC 164 | Singapore | Sentencing case under s 304(a) of the Penal Code. |
| PP v Ng Hua Chye | Singapore High Court | Yes | [2002] 4 SLR 412 | Singapore | Sentencing case under s 304(a) of the Penal Code. |
| Soong Hee Sin v PP | Court of Appeal | Yes | [2001] 2 SLR 253 | Singapore | Past sentencing cases are helpful, but every case must be looked at on its own unique facts. |
| Sim Gek Yong v PP | Court of Appeal | Yes | [1995] 1 SLR 537 | Singapore | Public interest is a primary consideration in the sentencing process. |
| PP v Mohd Azmi bin Ja’afar | Malaysian High Court | Yes | [2003] 2 MLJ 189 | Malaysia | It is not in the public interest to be lenient when the accused committed a most serious offence, although the accused was a first-time offender. |
| PP v Sundarti Supriyanto | Singapore High Court | Yes | [2004] 4 SLR 622 | Singapore | Analogous case involving a domestic worker convicted of culpable homicide. |
| PP v Sundarti Supriyanto (No 2) | Singapore High Court | Yes | [2004] SGHC 244 | Singapore | Analogous case involving a domestic worker convicted of culpable homicide and sentenced to life imprisonment. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Penal Code | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Culpable homicide
- Life imprisonment
- Aggravating factors
- Mitigating factors
- Premeditation
- Vulnerable victim
- Employer-domestic worker relationship
- Young offender
- Sentencing principles
15.2 Keywords
- culpable homicide
- life imprisonment
- domestic worker
- sentencing
- Singapore
- criminal law
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Criminal Law | 95 |
| Sentencing | 90 |
| Criminal Procedure | 90 |
| Culpable Homicide | 90 |
| Murder | 60 |
16. Subjects
- Criminal Law
- Sentencing
- Homicide