Public Prosecutor v Zurina bte Khairuddin: Sentencing Commencement for Offender Undergoing Reformative Training
In Public Prosecutor v Zurina bte Khairuddin, the High Court of Singapore heard an appeal by the Prosecution against the District Court's decision regarding the commencement of a three-week imprisonment sentence for Zurina Binte Khairuddin, who was already undergoing reformative training. The District Court had ordered the imprisonment to commence after the completion of the reformative training. Choo Han Teck J allowed the Prosecution's appeal, holding that the imprisonment term should commence immediately, from the date of the sentence.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Appeal Allowed
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal regarding the commencement date of imprisonment for an offender undergoing reformative training. The High Court held that the imprisonment term should commence immediately.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Public Prosecutor | Appellant | Government Agency | Appeal Allowed | Won | Jeyendran Jeyapal of Attorney-General’s Chambers |
| Zurina bte Khairuddin | Respondent | Individual | Appeal Dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Choo Han Teck | J | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Jeyendran Jeyapal | Attorney-General’s Chambers |
4. Facts
- Zurina Binte Khairuddin was sentenced to undergo reformative training in October 2005.
- In April 2008, she was placed in a halfway house for the supervision phase of her sentence.
- In May 2008, Zurina Binte Khairuddin absconded from the halfway house.
- She was charged with criminal breach of trust and pleaded guilty.
- The district judge sentenced her to three weeks’ imprisonment, to commence at the expiry of her reformative training sentence.
- The Prosecution appealed, arguing that the imprisonment should commence immediately.
5. Formal Citations
- Public Prosecutor v Zurina bte Khairuddin, MA 270/2008, [2009] SGHC 11
- PP v Zurina Binte Khairuddin, , [2008] SGDC 357
6. Timeline
| Date | Event |
|---|---|
| Zurina Binte Khairuddin sentenced to undergo reformative training. | |
| Zurina Binte Khairuddin placed in a halfway house. | |
| Zurina Binte Khairuddin absconded from the halfway house. | |
| District judge sentenced Zurina Binte Khairuddin to three weeks’ imprisonment. | |
| High Court allowed the Prosecution’s appeal. |
7. Legal Issues
- Commencement of Imprisonment Sentence
- Outcome: The court held that the term of imprisonment should commence immediately, from the date of the sentence, and run concurrently with the reformative training.
- Category: Procedural
8. Remedies Sought
- Imprisonment
9. Cause of Actions
- Criminal Breach of Trust
10. Practice Areas
- Criminal Law
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Ng Kwok Fai v PP | N/A | Yes | [1996] 1 SLR 568 | Singapore | Cited regarding the court's discretion to impose a nominal sentence of imprisonment to begin after the completion of reformative training, but distinguished because Schedule D of the Criminal Procedure Code was not addressed in that case. |
| PP v Zurina Binte Khairuddin | District Court | Yes | [2008] SGDC 357 | Singapore | The District Court case which is the subject of the current appeal. |
| PP v Mohammad Rohaizad bin Rosni | N/A | Yes | [1998] 3 SLR 804 | Singapore | Cited to support the view that a sentence of reformative training is distinct from a term of imprisonment. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Criminal Procedure Code (Cap 68, 1985 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Reformative Training
- Imprisonment
- Commencement of Sentence
- Criminal Procedure Code
- Schedule D
- Halfway House
- Recall Order
15.2 Keywords
- Criminal Law
- Sentencing
- Reformative Training
- Imprisonment
- Singapore
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Reformative Training | 95 |
| Sentencing | 90 |
| Criminal Procedure | 90 |
| Work Injury Compensation | 10 |
16. Subjects
- Criminal Law
- Sentencing
- Criminal Procedure