Law Society v Ng Bock Hoh Dixon: Misconduct Unbefitting Advocate & Solicitor for False Court Documents
The Law Society of Singapore applied to the High Court for disciplinary action against Ng Bock Hoh Dixon, an advocate and solicitor, for misconduct under the Legal Profession Act. Ng Bock Hoh Dixon pleaded guilty to preparing false court judgments to help a friend deceive his wife. The High Court, comprising Chan Sek Keong CJ, Andrew Phang Boon Leong JA, and V K Rajah JA, ordered that Ng Bock Hoh Dixon be suspended from practice for two years.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Respondent suspended from practice for two years; no order as to costs.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
The Law Society of Singapore sought disciplinary action against Ng Bock Hoh Dixon for creating false court documents. The court suspended him from practice for two years.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Law Society of Singapore | Applicant | Statutory Board | Application Allowed | Won | |
| Ng Bock Hoh Dixon | Respondent | Individual | Suspended from Practice | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Chan Sek Keong | Chief Justice | No |
| Andrew Phang Boon Leong | Justice of the Court of Appeal | Yes |
| V K Rajah | Justice of the Court of Appeal | No |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Vijai Dharamdas Parwani | Parwani & Co |
4. Facts
- The Respondent prepared two documents purporting to be draft judgments from the Subordinate Courts.
- The Respondent knew that these documents were false.
- The documents were stamped with the word “Draft”.
- The Respondent claimed he created the documents as part of a “wife placation exercise” for a friend.
- The Disciplinary Committee found that the Respondent’s conduct was dishonest and unbefitting of an advocate and solicitor.
- The Respondent pleaded guilty to the amended charges.
5. Formal Citations
- Law Society of Singapore v Ng Bock Hoh Dixon, Originating Summons No 1068 of 2009 (Summons No 5527 of 2009), [2010] SGHC 69
6. Timeline
| Date | Event |
|---|---|
| Complainant engaged the services of the Respondent to represent JCV Consultants. | |
| Complainant and Respondent met again and became business partners. | |
| Respondent prepared a document entitled Judgment between JCV Consultants and Nortel (S) Pte Ltd. | |
| Respondent prepared a document entitled Judgment between RJ Crocker Consultants Pte and Singapore Agro Agricultural Pte Ltd. | |
| Relationship between complainant and respondent soured. | |
| Complainant informed the Respondent via e-mail that he was terminating their business relationship. | |
| Complainant made a complaint to the Law Society against the Respondent. | |
| Originating Summons No 1068 of 2009 (Summons No 5527 of 2009) filed. | |
| High Court ordered that the Respondent be suspended from practice for two years. |
7. Legal Issues
- Misconduct Unbefitting an Advocate and Solicitor
- Outcome: The court found the respondent guilty of misconduct unbefitting an advocate and solicitor.
- Category: Substantive
- Sub-Issues:
- Creation of false court documents
- Breach of duty to the court
- Compromising the integrity of the administration of justice
8. Remedies Sought
- Order to show cause
- Disciplinary action
9. Cause of Actions
- Breach of Legal Profession Act
- Misconduct
10. Practice Areas
- Professional Responsibility
- Litigation
11. Industries
- Legal Services
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Law Society of Singapore v Dixon Ng Bock Hoh | Singapore Disciplinary Committee | Yes | [2009] SGDSC 4 | Singapore | Cited for the charges brought against the Respondent and his guilty plea. |
| Law Society of Singapore v Ng Chee Sing | Court of Appeal | Yes | [2000] 1 SLR(R) 466 | Singapore | Cited for the interpretation of Section 83(2)(h) of the Legal Profession Act as a catch-all provision. |
| Law Society of Singapore v Khushvinder Singh Chopra | Court of Appeal | Yes | [1998] 3 SLR(R) 490 | Singapore | Cited to differentiate between 'grossly improper conduct' and 'conduct unbefitting an advocate and solicitor'. |
| In re Weare, a Solicitor; In re The Solicitors Act, 1888 | Queen's Bench | Yes | [1893] 2 QB 439 | England and Wales | Cited for the standard of unbefitting conduct, where a solicitor need only be shown to have been guilty of such conduct as would render him unfit to remain as a member of an honourable profession. |
| Law Society of Singapore v Ahmad Khalis bin Abdul Ghani | Court of Appeal | Yes | [2006] 4 SLR(R) 308 | Singapore | Cited to emphasize that the focus of s 83(2)(h) is on the conduct of the solicitor and ensuring it meets high levels of professionalism. |
| Law Society of Singapore v Arjan Chotrani Bisham | Court of Appeal | Yes | [2001] 1 SLR(R) 231 | Singapore | Cited to establish that under s 83(2)(h) the solicitor’s misconduct has to be unbefitting an advocate and solicitor and that the standard of judgment to be applied is fixed by the court and is not the standard of peer judgment. |
| Law Society of Singapore v Ong Ying Ping | Court of Appeal | Yes | [2005] 3 SLR(R) 583 | Singapore | Cited for the principle that the ends do not justify the means when improper methods are used. |
| Narindar Singh Kang v Law Society of Singapore | Court of Appeal | Yes | [2007] 4 SLR(R) 641 | Singapore | Cited for the solemn declaration made by lawyers and the duty to exercise knowledge and skills truly and honestly. |
| Bolton v Law Society | English Court of Appeal | Yes | [1994] 1 WLR 512 | England and Wales | Cited for the principle that any solicitor who is shown to have discharged his professional duties with anything less than complete integrity, probity and trustworthiness must expect severe sanctions to be imposed upon him. |
| Law Society of Singapore v Ravindra Samuel | Court of Appeal | Yes | [1999] 1 SLR(R) 266 | Singapore | Cited for assessing the gravity of the misconduct and the severity of the penalty. |
| Law Society of Singapore v Wee Wei Fen | Court of Appeal | Yes | [1999] 3 SLR(R) 559 | Singapore | Cited to contrast the facts with the present proceedings, where the lawyer was convicted of forgery and cheating. |
| Re Advani Jiwat G | High Court | Yes | [1988] 1 SLR(R) 98 | Singapore | Cited to contrast the facts with the present proceedings, where the lawyer prepared a forged will. |
| Law Society of Singapore v Tan Buck Chye Dave | Court of Appeal | Yes | [2007] 1 SLR(R) 581 | Singapore | Cited as reference. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Legal Profession Act (Cap 161, 2001 Rev Ed) s 83(2)(h) | Singapore |
| Legal Profession Act (Cap 161, 2001 Rev Ed) s 82(1) | Singapore |
| Legal Profession Act (Cap 161, 2001 Rev Ed) s 24 | Singapore |
| Legal Profession Act (Cap 161, 2001 Rev Ed) ss 94(1) | Singapore |
| Legal Profession Act (Cap 161, 2001 Rev Ed) ss 98(1) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Misconduct unbefitting an advocate and solicitor
- False court documents
- Wife placation exercise
- Integrity of the administration of justice
- Officer of the Supreme Court
15.2 Keywords
- Legal Profession Act
- Misconduct
- Advocate and Solicitor
- Disciplinary Committee
- False Court Documents
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Legal Profession Act | 90 |
| Professional Ethics | 85 |
| Legal Ethics and Professional Responsibility | 80 |
| Professional Misconduct | 75 |
| Forgery | 60 |
| Fraud and Deceit | 50 |
| Breach of Duty | 40 |
16. Subjects
- Legal Profession
- Ethics
- Disciplinary Action