Amutha Valli v Redemptorist Fathers: Tort Claims for Assault, False Imprisonment & Negligence in Alleged Exorcism

Amutha Valli d/o Krishnan sued the Titular Superior of the Redemptorist Fathers in Singapore and others in the High Court of Singapore, alleging assault and battery, false imprisonment, and negligence following an incident at the Novena Church on August 10, 2004. Valli claimed she was subjected to an unauthorized exorcism. Lee Seiu Kin J dismissed all claims, finding the defendants' version of events more credible and that their actions were reasonable in the circumstances.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Claim dismissed

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Amutha Valli sued the Redemptorist Fathers for assault, false imprisonment, and negligence after an alleged exorcism. The court dismissed all claims.

1.7 Decision Date

12 February 2009

2. Parties and Outcomes

Party Name	Role	Type	Outcome	Outcome Type	Counsels
Amutha Valli d/o Krishnan	Plaintiff	Individual	Claim dismissed	Lost	Raj Singh Shergill of Lee Shergill Partnership Ragbir Singh Bajwa of Bajwa & Co Anuradha Tiwary of Bajwa & Co
Titular Superior of the Redemptorist Fathers in Singapore	Defendant	Corporation	Judgment for Defendant	Won	P Padman of Tito Isaac & Co LLP Tito Isaac of Tito Isaac & Co LLP
Simon Tan Hon Lip	Defendant	Individual	Judgment for Defendant	Won	P Padman of Tito Isaac & Co LLP Tito Isaac of Tito Isaac & Co LLP
Jacob Ong Siong Teck	Defendant	Individual	Judgment for Defendant	Won	Darrell Low of Drew & Napier LLC Jimmy Yim SC of Drew & Napier LLC Cosmas Gomez of Cosmas & Co
Nasrom Bin Abdullah	Defendant	Individual	Judgment for Defendant	Won	Anthony Lee Hwee Khiam of Bih Li & Lee Cosmas Gomez of Cosmas & Co
Francis Chian Kim Fook	Defendant	Individual	Judgment for Defendant	Won	Denis Tan of Toh Tan LLP George John of Toh Tan LLP
Koh Cheng Swee	Defendant	Individual	Judgment for Defendant	Won	Denis Tan of Toh Tan LLP George John of Toh Tan LLP
Benny Tan Chin Beng	Defendant	Individual	Judgment for Defendant	Won	Anthony Lee Hwee Khiam of Bih Li & Lee Cosmas Gomez of Cosmas & Co
Choo Joke Li	Defendant	Individual	Judgment for Defendant	Won	Denis Tan of Toh Tan LLP George John of Toh Tan LLP
Cheong Lai Meng	Defendant	Individual	Judgment for Defendant	Won	Anthony Lee Hwee Khiam of Bih Li & Lee Cosmas Gomez of Cosmas & Co

3. Judges

Judge Name	Title	Delivered Judgment
Lee Seiu Kin	Judge	Yes

4. Counsels

Counsel Name	Organization
Raj Singh Shergill	Lee Shergill Partnership
Ragbir Singh Bajwa	Bajwa & Co
Anuradha Tiwary	Bajwa & Co
P Padman	Tito Isaac & Co LLP
Tito Isaac	Tito Isaac & Co LLP
Darrell Low	Drew & Napier LLC
Jimmy Yim SC	Drew & Napier LLC
Cosmas Gomez	Cosmas & Co
Anthony Lee Hwee Khiam	Bih Li & Lee
Denis Tan	Toh Tan LLP
George John	Toh Tan LLP

4. Facts

Plaintiff went to the Church of Saint Alphonsus with her son, daughter, and a family friend.
Plaintiff fainted at the church.
Priests Tan and Ong suggested taking the plaintiff to a room to rest.
Tan and Ong told the family members that the plaintiff was possessed.
Defendants conducted what they believed to be an exorcism.
Plaintiff claimed she was forcibly pinned down and verbally abused.
Defendants claimed they were trying to restrain the plaintiff from hurting herself.

5. Formal Citations

Amutha Valli d/o Krishnan v Titular Superior of the Redemptorist Fathers in Singapore and Others, Suit 531/2006, [2009] SGHC 35

6. Timeline

Date	Event
1956-01-01	Plaintiff born
1972-01-01	Plaintiff completed 'O' levels
1977-01-01	Plaintiff married Suppiah Jeyabal
1979-01-01	Plaintiff's son, Jairaj, born
1985-01-01	Plaintiff's daughter, Subashini, born
1986-01-01	Plaintiff began treatment at National University Hospital
1989-01-01	Plaintiff left Telecommunications Authority of Singapore
1990-01-01	Plaintiff worked as a private tutor
2000-05-01	Plaintiff admitted to Institute for Mental Health
2002-01-01	Simon Tan appointed Titular Superior of the Order of the Redemptorist Fathers of Singapore
2004-08-10	Incident at the Church of Saint Alphonsus
2004-08-11	Plaintiff made a police report
2004-09-03	Plaintiff began treatment with Prof Ong
2005-04-01	Plaintiff referred to Dr Chan for a second opinion
2006-10-01	Plaintiff requested IMH for a medical report
2006-11-10	Plaintiff filed answers to interrogatories
2007-10-31	Trial began
2008-06-23	Mr Bajwa applied for the cross-examination of the plaintiff to be dispensed with
2009-02-13	Judgment reserved

7. Legal Issues

Assault and Battery
- Outcome: The court found that there was no assault or battery as the defendants' actions were to restrain the plaintiff from hurting herself and they had implied consent.
- Category: Substantive
- Sub-Issues:
  - Apprehension of immediate unlawful force
  - Actual infliction of unlawful force
  - Implied consent
  - Doctrine of necessity
  - Reasonableness of force applied
- Related Cases:
  - [1984] 1 WLR 1172
False Imprisonment
- Outcome: The court found that the plaintiff was not prevented from leaving the room.
- Category: Substantive
- Sub-Issues:
  - Prevention from leaving premises
Negligence
- Outcome: The court found that while the defendants owed the plaintiff a duty of care, they did not breach that duty and the plaintiff did not suffer damage as a result of their actions.
- Category: Substantive
- Sub-Issues:
  - Duty of care
  - Legal proximity
  - Policy considerations
  - Breach of duty of care
  - Causation of damage
- Related Cases:
  - [2007] 4 SLR 100
  - (1985) 60 ALR 1

8. Remedies Sought

Damages
Special Damages
Aggravated Damages

9. Cause of Actions

Assault and Battery
False Imprisonment
Negligence

10. Practice Areas

Litigation
Religious Institutions Law

11. Industries

Religious Organizations

12. Cited Cases

Case Name	Court	Affirmed	Citation	Jurisdiction	Significance
Collins v Wilcock	N/A	Yes	[1984] 1 WLR 1172	N/A	Cited for the definition of assault and battery.
R v Bournewood Community and Mental Health Services Trust Exp L	N/A	Yes	[1999] 1 AC 458	N/A	Cited regarding the common law doctrine of necessity.
Spandeck Engineering (S) Pte Ltd v Defence Science & Technology Agency	Court of Appeal	Yes	[2007] 4 SLR 100	Singapore	Cited for the two-stage test to determine the imposition of a duty of care.
Sutherland Shire Council v Heyman	High Court of Australia	Yes	(1985) 60 ALR 1	Australia	Cited regarding the requirement of proximity in determining duty of care.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute Name	Jurisdiction
Redemptorist Fathers Ordinance (Cap 374, 1985 Rev Ed)	Singapore
Rules of Court (Cap 322, R5, 2004 Rev Ed)	Singapore

15. Key Terms and Keywords

15.1 Key Terms

Exorcism
Possession
Redemptorist Fathers
Novena Church
Duty of Care
Assault
Battery
False Imprisonment
Negligence
PTSD

15.2 Keywords

assault
battery
false imprisonment
negligence
exorcism
possession
church
priest
tort
Singapore

17. Areas of Law

Area Name	Relevance Score
Torts	80
Negligence	70
Assault	70
False Imprisonment	70
Psychiatry	40
Civil Procedure	30
Medical Negligence	30
Evidence Law	30

16. Subjects

Tort Law
Religious Law
Civil Litigation