Ramalingam Ravinthran v PP: Trafficking of Cannabis and Cannabis Mixture
In Ramalingam Ravinthran v Public Prosecutor, the Court of Appeal of Singapore heard an appeal by Ramalingam Ravinthran against his conviction in the High Court for two charges of trafficking in a controlled drug, specifically cannabis and cannabis mixture. The prosecution argued that Ravinthran had actual knowledge of the drugs in his possession and was wilfully blind to their presence. The Court of Appeal dismissed the appeal, finding that the trial judge was entitled to conclude that Ravinthran had actual knowledge that he was trafficking in cannabis and cannabis mixture.
1. Case Overview
1.1 Court
Court of Appeal1.2 Outcome
Appeal Dismissed
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Ramalingam Ravinthran appeals against his conviction for trafficking cannabis and cannabis mixture. The court dismissed the appeal, finding he had actual knowledge of the drugs.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Public Prosecutor | Respondent | Government Agency | Appeal Dismissed | Won | Kevin Yong of Attorney-General’s Chambers Mark Tay of Attorney-General’s Chambers Prem Raj s/o Prabakaran of Attorney-General’s Chambers |
| Ramalingam Ravinthran | Appellant | Individual | Appeal Dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Chan Sek Keong | Chief Justice | Yes |
| Andrew Phang Boon Leong | Justice of the Court of Appeal | No |
| V K Rajah | Justice of the Court of Appeal | No |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Kevin Yong | Attorney-General’s Chambers |
| Mark Tay | Attorney-General’s Chambers |
| Prem Raj s/o Prabakaran | Attorney-General’s Chambers |
| Suresh Damodara | Damodara, Hazra, K Sureshan LLP |
| Leonard Hazra | Damodara, Hazra, K Sureshan LLP |
| Jeyapalan Ayaduray | Jeya & Associates |
4. Facts
- Appellant was arrested after a car chase.
- A sports bag containing cannabis and cannabis mixture was found in the appellant's car.
- Appellant stated 'The Grass' when asked what was in the bag.
- Sundar stated that the appellant told him the bag contained ganja.
- Appellant had transported a bag from the SAS Temple to Hawkerway Food Court previously.
- Appellant received $4,000 from Abang to give to Sundar.
- Appellant suspected the bag contained something illegal but did not inspect it.
5. Formal Citations
- Ramalingam Ravinthran v Public Prosecutor, Criminal Appeal No 28 of 2009, [2011] SGCA 14
- Public Prosecutor v Ramalingam Ravinthran, , [2009] SGHC 265
- Tan Kiam Peng v PP, , [2008] 1 SLR 1
6. Timeline
| Date | Event |
|---|---|
| Appellant set up labour supply business. | |
| Appellant introduced to labour supply contractors in Malaysia. | |
| Appellant met Anand and Kumar in Johor Bahru. | |
| Appellant invited to nightclub in Johor Bahru. | |
| Kumar asked appellant to transport a bag. | |
| Appellant transported a bag from SAS Temple to Hawkerway Food Court. | |
| Appellant received call from Tamby. | |
| Appellant met Sundar at SAS Temple. | |
| Appellant arrested. | |
| Vegetable blocks handed over to analysts at Health Sciences Authority. | |
| Urine samples taken from appellant handed over to the HSA. | |
| Statement recorded from Sundar. | |
| Cautioned statement recorded from the appellant. | |
| Investigation statement recorded from the appellant. | |
| Moy Hooi Yan certified urine samples to contain tetrahydrocannibinol. | |
| Lim Cheng Min certified urine samples to contain tetrahydrocannibinol. | |
| Sundar admitted to a statement of facts. | |
| Sundar pleaded guilty to two charges of trafficking in cannabis. | |
| Further investigation statement taken from Sundar. | |
| High Court decision. | |
| Court of Appeal dismissed the appeal. |
7. Legal Issues
- Knowledge of Drug Possession
- Outcome: The court found that the appellant had actual knowledge that the sports bag contained cannabis and cannabis mixture, and alternatively, was wilfully blind to that fact.
- Category: Substantive
- Sub-Issues:
- Wilful Blindness
- Inference of Knowledge
- Presumption of Trafficking
- Outcome: The court found that the appellant did not rebut the presumption that the drugs were in his possession for the purpose of trafficking.
- Category: Substantive
- Admissibility of Accomplice Evidence
- Outcome: The court found Sundar's statement that the appellant told him the sports bag contained ganja is admissible, and is truthful.
- Category: Procedural
8. Remedies Sought
- Appeal against conviction
- Appeal against sentence
9. Cause of Actions
- Drug Trafficking
10. Practice Areas
- Criminal Litigation
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Public Prosecutor v Ramalingam Ravinthran | High Court | Yes | [2009] SGHC 265 | Singapore | The judgment being appealed from. |
| Tan Kiam Peng v Public Prosecutor | Court of Appeal | Yes | [2008] 1 SLR(R) 1 | Singapore | Cited for the principle of wilful blindness. |
| Public Prosecutor v Victor Rajoo | Court of Appeal | Yes | [1995] 3 SLR(R) 189 | Singapore | Cited for the principle that an appellate court will not disturb findings of fact unless plainly wrong. |
| Public Prosecutor v Mohammed Liton Mohammed Syeed Mallik | Court of Appeal | Yes | [2008] 1 SLR(R) 601 | Singapore | Cited for the principle that an appellate court will not disturb findings of fact unless plainly wrong. |
| Tan Ah Tee and another v Public Prosecutor | Court of Appeal | Yes | [1979–1980] SLR(R) 311 | Singapore | Cited regarding the inference of knowledge based on possession and opportunity to inspect contents. |
| Warner v Metropolitan Police Commissioner | House of Lords | Yes | [1969] 2 AC 256 | United Kingdom | Cited regarding the inference of knowledge based on possession and opportunity to inspect contents. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Misuse of Drugs Act (Cap 185, 2001 Rev Ed) s 5(1)(a) | Singapore |
| Misuse of Drugs Act (Cap 185, 2001 Rev Ed) s 33 | Singapore |
| Misuse of Drugs Act (Cap 185, 2001 Rev Ed) Second Schedule | Singapore |
| Misuse of Drugs Act (Cap 185, 2001 Rev Ed) s 17 | Singapore |
| Evidence Act (Cap 97, 1997 Rev Ed) s 156 | Singapore |
| Evidence Act (Cap 97, 1997 Rev Ed) s 147 | Singapore |
| Criminal Procedure Code (Cap 68, 1985 Rev Ed) s 122(6) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Cannabis
- Cannabis Mixture
- Drug Trafficking
- Wilful Blindness
- Actual Knowledge
- Possession
- Sports Bag
- Accomplice Evidence
- Presumption of Trafficking
15.2 Keywords
- Drug Trafficking
- Cannabis
- Singapore
- Criminal Law
- Appeal
- Misuse of Drugs Act
- Wilful Blindness
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Misuse of Drugs Act | 95 |
| Drug Trafficking | 95 |
| Criminal Law | 90 |
| Controlled Drugs | 90 |
| Evidence Law | 60 |
16. Subjects
- Criminal Law
- Drug Trafficking