PP v Sarle Steepan: Culpable Homicide Sentencing for Infant Death
In Public Prosecutor v Sarle Steepan, the High Court of Singapore sentenced Sarle Steepan to 18 years' imprisonment and 16 strokes of the cane for culpable homicide not amounting to murder. The accused pleaded guilty to causing the death of a two-month-old baby by applying blunt force to her head. The court considered the accused's deception in obtaining custody of the baby, the vulnerability of the victim, and the horrific injuries inflicted. The court also took into account a charge of having made a false joint statutory declaration with the mother of the deceased baby.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Accused sentenced to 18 years’ imprisonment and 16 strokes of the cane.
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Sarle Steepan was sentenced to 18 years' imprisonment and 16 strokes of the cane for culpable homicide after causing the death of a two-month-old baby.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Public Prosecutor | Prosecution | Government Agency | Judgment for Prosecution | Won | Leong Wing Tuck, Diane Tan, Edmund Lam |
| Sarle Steepan s/o Kolundu | Defendant | Individual | Convicted | Lost | Ronald Ng, Jeeva Arul Joethy |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Tay Yong Kwang | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Leong Wing Tuck | Attorney-General's Chambers |
| Diane Tan | Attorney-General's Chambers |
| Edmund Lam | Attorney-General's Chambers |
| Ronald Ng | Ng Lee & Partners |
| Jeeva Arul Joethy | Joethy & Co |
4. Facts
- The accused slapped and dropped the two-month-old victim.
- The accused was angry with the mother of the victim for cheating on him.
- The accused falsely declared that he was the biological father of the baby.
- The accused consumed alcohol before the incident.
- The baby sustained facial injuries and severe head injury.
- The accused obtained custody of the baby by deception.
- The accused has a drug history going back to 1990.
5. Formal Citations
- Public Prosecutor v Sarle Steepan s/o Kolundu, CC 39/2009, [2009] SGHC 207
6. Timeline
| Date | Event |
|---|---|
| Accused born | |
| Accused and Jennifer got to know each other | |
| Accused and Jennifer moved out of flat | |
| Jennifer applied for a Personal Protection Order against the accused | |
| Jennifer gave birth to the baby | |
| Accused falsely declared he was the biological father of the baby | |
| Accused visited Jennifer and the baby at Good Shepherd Centre | |
| Accused caused the death of the baby | |
| Accused arrested | |
| Accused and Jennifer were supposed to be married | |
| Judgment issued |
7. Legal Issues
- Appropriate sentence for culpable homicide
- Outcome: The court sentenced the accused to 18 years’ imprisonment and 16 strokes of the cane.
- Category: Substantive
8. Remedies Sought
- Sentencing
9. Cause of Actions
- Culpable Homicide Not Amounting to Murder
10. Practice Areas
- Criminal Law
- Sentencing
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| PP v Raffi bin Jelan and Another | High Court | Yes | [2004] SGHC 120 | Singapore | Cited for the need to protect vulnerable victims such as children. |
| Purwanti Parji v PP | High Court | Yes | [2005] 2 SLR 220 | Singapore | Cited for the need to protect vulnerable victims such as children. |
| PP v Wong Siu Fai | High Court | Yes | [2002] 3 SLR 276 | Singapore | Cited regarding the effect of intoxication on planned modus operandi. |
| PP v Mohammad Zam bin Abdul Rashid | High Court | Yes | [2006] SGHC 168 | Singapore | Cited regarding life imprisonment for accused with unstable mental condition. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| section 304(a) of the Penal Code, Chapter 224 | Singapore |
| s 14(1)(ii) of the Oaths and Declarations Act (Cap 211, 2001 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Culpable homicide
- Blunt force trauma
- Infant death
- False declaration
- Intoxication
- Mitigation
- Aggravating factors
15.2 Keywords
- Culpable homicide
- Infant death
- Sentencing
- Singapore
- Criminal law
16. Subjects
- Criminal Law
- Sentencing
17. Areas of Law
- Criminal Law
- Sentencing
- Culpable Homicide