Chee Siok Chin v Attorney-General: Application for Judge Recusal Due to Potential Bias
Ms. Chee Siok Chin and Mr. Chee Soon Juan applied for a declaration that the deletion of O 14 r 1(2) of the Rules of the Supreme Court was unconstitutional. The application and related summary judgment applications were scheduled to be heard in the High Court of Singapore before Woo Bih Li J. The Applicants sought the judge's recusal based on a potential bias due to a past incident between their counsel, Mr. M Ravi, and the judge. Woo Bih Li J granted the application and recused himself.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Application granted; judge recused himself.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Application for judge to recuse himself due to potential bias arising from a prior exchange between counsel and judge. The judge recused himself.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Attorney-General | Respondent | Government Agency | Application granted | Lost | Jeffrey Chan of Attorney-General’s Chambers |
| Chee Soon Juan | Applicant | Individual | Application granted | Won | |
| Chee Siok Chin | Applicant | Individual | Application granted | Won |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Woo Bih Li | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Jeffrey Chan | Attorney-General’s Chambers |
| M Ravi | M Ravi & Co |
4. Facts
- Applicants are defendants in defamation suits.
- Applicants learned that plaintiffs were considering applying for summary judgment.
- Applicants applied for a declaration that the deletion of O 14 r 1(2) of the Rules of the Supreme Court was unconstitutional.
- Applicants' counsel applied for the judge to recuse himself based on a suspicion or likelihood of bias.
- The bias claim arose from a prior acrimonious exchange between the judge and counsel.
5. Formal Citations
- Chee Siok Chin and Another v Attorney-General, OS 1203/2006, [2006] SGHC 144
6. Timeline
| Date | Event |
|---|---|
| Acrimonious exchange between Mr. M Ravi and Woo Bih Li J. | |
| Originating summons and applications for summary judgment fixed for hearing. | |
| Application for judge to recuse himself. | |
| Judge recused himself. |
7. Legal Issues
- Judicial Recusal
- Outcome: The judge recused himself in the interest of justice.
- Category: Procedural
- Sub-Issues:
- Suspicion of bias
- Likelihood of bias
8. Remedies Sought
- Declaration that the deletion or repeal of O 14 r 1(2) of the Rules of the Supreme Court 1970 is a breach of principles of natural justice and unconstitutional.
9. Cause of Actions
- No cause of actions
10. Practice Areas
- Civil Procedure
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Jeyaretnam v Government | N/A | Yes | N/A | N/A | Cited as an example of a previous recusal application, but distinguished on its facts. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Rules of the Supreme Court 1970 (Act 24 of 1969, S 274/1970) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Recusal
- Bias
- Suspicion of bias
- Likelihood of bias
- Natural justice
15.2 Keywords
- Recusal
- Bias
- Judge
- Attorney-General
- Singapore
- High Court
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Recusal | 90 |
| Civil Procedure | 70 |
| Jurisdiction | 60 |
| Defamation | 40 |
| Contract Law | 30 |
| Duty of Candour | 25 |
| Administrative Law | 20 |
16. Subjects
- Judicial Review
- Civil Procedure