Attorney-General v Tan Liang Joo John: Contempt of Court for Scandalizing Judiciary with Kangaroo T-Shirt
In Attorney-General v Tan Liang Joo John, Isrizal Bin Mohamed Isa, and Muhammad Shafi'ie Syahmi Bin Sariman, the High Court of Singapore, presided over by Judith Prakash J, found the respondents liable for contempt of court on 24 November 2008. The respondents scandalized the judiciary by wearing a T-shirt imprinted with a picture of a kangaroo dressed in a judge’s gown within and in the vicinity of the Supreme Court. The court sentenced the First Respondent to 15 days in prison and the Second and Third Respondents to seven days in prison each.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Respondents found liable for contempt of court.
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Tan Liang Joo John and others were found liable for contempt of court for scandalizing the judiciary by wearing a kangaroo T-shirt.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Attorney-General | Applicant | Government Agency | Judgment for Applicant | Won | Gillian Koh Tan of Attorney-General’s Chambers Jeffrey Chan Wah Teck of Attorney-General’s Chambers Lee Jwee Nguan of Attorney-General’s Chambers Jennifer Marie of Attorney-General’s Chambers |
| Tan Liang Joo John | Respondent | Individual | Liable for Contempt of Court | Lost | |
| Muhammad Shafi’ie Syahmi Bin Sariman | Respondent | Individual | Liable for Contempt of Court | Lost | |
| Isrizal Bin Mohamed Isa | Respondent | Individual | Liable for Contempt of Court | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Judith Prakash | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Gillian Koh Tan | Attorney-General’s Chambers |
| Jeffrey Chan Wah Teck | Attorney-General’s Chambers |
| Lee Jwee Nguan | Attorney-General’s Chambers |
| Jennifer Marie | Attorney-General’s Chambers |
| Chia Ti Lik | Chia Ngee Thuang & Co |
4. Facts
- Respondents wore T-shirts with a kangaroo dressed as a judge in the Supreme Court.
- The T-shirt was worn during the assessment of damages hearing for a defamation case.
- First Respondent allegedly said, “This is a kangaroo court” to Minister Mentor Lee Kuan Yew.
- A photograph of the respondents wearing the T-shirts was posted on the SDP website.
- Respondents refused to apologize for their actions.
- First Respondent distributed similar T-shirts inside the Supreme Court on 26 May 2008.
5. Formal Citations
- Attorney-General v Tan Liang Joo John and Others, OS 1242/2008, 1244/2008, 1246/2008, [2009] SGHC 41
6. Timeline
| Date | Event |
|---|---|
| Orders made for the applications to be tried at the same time | |
| Respondents wore contemning T-shirt in Supreme Court | |
| First Respondent wore contemning T-shirt in Supreme Court | |
| SDP article posted on SDP website | |
| Hearing regarding striking out affidavits | |
| Respondents found liable for contempt of court | |
| Submissions on sentence heard | |
| Decision Date |
7. Legal Issues
- Contempt of Court
- Outcome: Respondents found liable for contempt of court for scandalizing the judiciary.
- Category: Substantive
- Fair Criticism
- Outcome: The court held that the respondents' actions did not constitute fair criticism.
- Category: Substantive
8. Remedies Sought
- Orders of committal
9. Cause of Actions
- Contempt of Court
10. Practice Areas
- Criminal Litigation
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Attorney-General v Pang Cheng Lian | Singapore Court | Yes | [1972-74] SLR 658 | Singapore | Cited as settled law in Singapore that it is a contempt of court to scandalise a court or judge. |
| Attorney-General v Wong Hong Toy | Singapore Court | Yes | [1982-1983] SLR 398 | Singapore | Cited as settled law in Singapore that it is a contempt of court to scandalise a court or judge. |
| Attorney-General v Zimmerman | Singapore Court | Yes | [1984-85] SLR 814 | Singapore | Cited as settled law in Singapore that it is a contempt of court to scandalise a court or judge. |
| Attorney-General v Wain (No 1) | Singapore Court | Yes | [1991] SLR 383 | Singapore | Cited as settled law in Singapore that it is a contempt of court to scandalise a court or judge and for the classic exposition of the law. |
| Attorney-General v Lingle | Singapore Court | Yes | [1995] 1 SLR 696 | Singapore | Cited as settled law in Singapore that it is a contempt of court to scandalise a court or judge. |
| Attorney-General v Chee Soon Juan | Singapore Court | Yes | [2006] 2 SLR 650 | Singapore | Cited as settled law in Singapore that it is a contempt of court to scandalise a court or judge. |
| Lee Hsien Loong v Singapore Democratic Party | High Court of Singapore | Yes | [2008] SGHC 173 | Singapore | Cited as settled law in Singapore that it is a contempt of court to scandalise a court or judge. |
| R v Gray | Queen's Bench Division | Yes | [1900] 2 QB 36 | England and Wales | Cited for the classic exposition of the law on contempt of court. |
| Gallagher v Durack | High Court of Australia | Yes | (1983) 45 ALR 53 | Australia | Cited for the principle that the authority of the law rests on public confidence. |
| Attorney-General v Hertzberg Daniel | High Court of Singapore | Yes | [2008] SGHC 218 | Singapore | Cited for the principle that to establish contempt the law does not require that a complainant prove that the act or words created a real risk of prejudicing the administration of justice. |
| Ambard v Attorney-General of Trinidad and Tobago | Judicial Committee of the Privy Council | Yes | [1936] 1 All ER 704 | Trinidad and Tobago | Cited for the principle that fair criticism does not amount to contempt of court. |
| R v White | English Court | Yes | (1808) 1 Camp 359n | England and Wales | Cited for the principle that criticism must be supported by argument and evidence. |
| R v Police Commissioner of the Metropolis, Ex parte Blackburn (No. 2) | English Court | Yes | [1968] 2 WLR 1204 | England and Wales | Cited for the principle that criticism of a judgment, however vigorous, cannot amount to contempt of court, providing it keeps within the limits of reasonable courtesy and good faith. |
| Wong Yeung Ng v Secretary for Justice | Hong Kong Court of Appeal | Yes | [1999] 2 HKC 24 | Hong Kong | Cited for the principle that scurrilous and preposterous attacks are likely to have the opposite effect on the administration of justice. |
| Solicitor-General v Radio Avon Ltd | New Zealand Court | No | [1978] 1 NZLR 225 | New Zealand | Cited for the view that the second limit on the right to criticise is unnecessary and potentially overly restrictive of legitimate criticism. |
| You Xin v Public Prosecutor | Singapore Court | Yes | [2007] 4 SLR 17 | Singapore | Cited as an example of physical acts that have been held to scandalise the court. |
| Secretary for Justice v Choy Bing Wing | Hong Kong Court | Yes | [2005–06] 11 HKPLR 480 | Hong Kong | Cited as an example of spoken words that have been held to scandalise the court. |
| Mafart v Television New Zealand Ltd | New Zealand Court | Yes | [2006] 3 NZLR 534 | New Zealand | Cited for the principle that images can convey messages and meaning by implication and association. |
| Australian Capital Television Pty Ltd v Commonwealth of Australia (No 2) | High Court of Australia | Yes | (1992) 108 ALR 577 | Australia | Cited for the principle that images can convey messages and meaning by implication and association. |
| Solicitor-General v Radio New Zealand Ltd | New Zealand Court | Yes | [1994] 1 NZLR 48 | New Zealand | Cited as an example of contempt of court committed by broadcast on television or radio. |
| Attorney-General v Blomfield | New Zealand Court | Yes | (1914) 33 NZLR 545 | New Zealand | Cited as an example of pictures that have been held to scandalise the court. |
| Soong Hee Sin v PP | Singapore Court | Yes | [2001] 2 SLR 253 | Singapore | Cited for the principle that the appropriate sentence can only be determined by looking at the particular facts of each case. |
| Knight v Public Prosecutor | Singapore Court | Yes | [1992] 1 SLR 720 | Singapore | Cited for the principle that loss of employment will generally not be taken into account except in special cases. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Supreme Court of Judicature Act | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Contempt of court
- Scandalizing the court
- Kangaroo court
- Fair criticism
- T-shirt
- Supreme Court
- Judiciary
15.2 Keywords
- Contempt of court
- Scandalizing judiciary
- Kangaroo T-shirt
- Singapore
- High Court
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Civil Contempt | 95 |
| Contempt of Court | 90 |
| Defamation | 10 |
16. Subjects
- Contempt of Court
- Criminal Law
- Judiciary