Law Society v Ng Bock Hoh Dixon: Disciplinary Action for False Bill & Integrity Breach

The Law Society of Singapore applied for disciplinary action against Mr. Dixon Ng Bock Hoh for professional misconduct. The High Court, comprising Chao Hick Tin JA, Andrew Phang Boon Leong JA, and V.K. Rajah JA, found Mr. Ng liable for creating a false bill and failing to cooperate honestly with the Law Society and his accountant. The court ordered Mr. Ng to be struck off the roll of advocates and solicitors, citing a breach of the required standards of integrity, probity, and trustworthiness.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Respondent struck off the roll of advocates and solicitors.

1.3 Case Type

Regulatory

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

The Law Society sought disciplinary action against Ng Bock Hoh Dixon for creating a false bill. The court ordered him struck off the roll due to integrity breach.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Law Society of SingaporeApplicantStatutory BoardOrder for Respondent to be struck off the roll grantedWon
Ng Bock Hoh DixonRespondentIndividualStruck off the roll of advocates and solicitorsLost

3. Judges

Judge NameTitleDelivered Judgment
Chao Hick TinJustice of the Court of AppealYes
Andrew Phang Boon LeongJustice of the Court of AppealYes
V K RajahJustice of the Court of AppealYes

4. Counsels

Counsel NameOrganization
Abraham VergisDrew & Napier LLC
Sushil Sukumaran NairDrew & Napier LLC
Kimberley LengDrew & Napier LLC

4. Facts

  1. The Respondent was an advocate and solicitor of the Supreme Court.
  2. The Law Society filed charges against the Respondent for professional misconduct.
  3. The Respondent created a false bill for US$100,000.
  4. The Respondent failed to honestly cooperate with the Law Society and his accountant.
  5. The Disciplinary Tribunal found the Respondent liable for creating a false bill and failing to cooperate honestly.
  6. The Respondent had previously been suspended for falsifying a judgment.
  7. The Respondent submitted that he was being rehabilitated through counselling and work for senior lawyers.

5. Formal Citations

  1. Law Society of Singapore v Ng Bock Hoh Dixon, Originating Summons No 442 of 2011, [2011] SGHC 242
  2. The Law Society of Singapore v Ng Bock Hoh Dixon, , [2011] SGDT 7
  3. Law Society of Singapore v Ng Bock Hoh Dixon, , [2010] 2 SLR 1000
  4. Law Society of Singapore v Nor'ain bte Abu Bakar and others, , [2009] 1 SLR(R) 753
  5. Law Society of Singapore v Ng Chee Sing, , [2000] 1 SLR(R) 466
  6. Law Society of Singapore v Lim Cheong Peng, , [2006] 4 SLR(R) 360
  7. Law Society of Singapore v Ravindra Samuel, , [1999] 1 SLR(R) 266
  8. Law Society of Singapore v Tay Eng Kwee Edwin, , [2007] 4 SLR(R) 171
  9. Law Society of Singapore v Low Yong Sen, , [2009] 1 SLR(R) 802
  10. Public Prosecutor v Boon Kiah Kin, , [1993] 2 SLR(R) 26
  11. Bolton v Law Society, , [1994] 1 WLR 512

6. Timeline

DateEvent
Complainant sent letter to Respondent's law firm setting out terms of Stakeholding Agreement.
Respondent accepted terms of Stakeholding Agreement by signing a copy of the January 2006 Letter.
Complainant paid US$100,000 to Respondent’s law firm.
Deadline for payment of Consultancy Fee Deposit.
Alleged date of payment to Seng Phally.
Expiry date of engagement set out in the January 2006 Letter.
Council of the Law Society exercised its powers to conduct an investigative audit into the accounts of the Respondent’s law firm.
Complainant gave Respondent written notice that the engagement had not yielded satisfactory results and demanded repayment of Consultancy Fee Deposit.
Complainant lodged a complaint with the Law Society.
Respondent wrote a letter to the inquiry committee.
Respondent appeared before a court of three Judges for the show cause proceedings in respect of the False Judgment Disciplinary Proceedings.
Court of three Judges suspended the Respondent from practice for a period of two years for preparing two draft court judgments purportedly issued by the Subordinate Courts of Singapore which he knew were false.
High Court ordered that the Respondent be struck off the roll of advocates and solicitors of the Supreme Court.

7. Legal Issues

  1. Breach of Professional Conduct
    • Outcome: The court found the Respondent had breached professional conduct by creating a false bill and failing to cooperate honestly with the Law Society and his accountant.
    • Category: Substantive
    • Sub-Issues:
      • Creating false documents
      • Failure to cooperate with Law Society
      • Failure to provide accurate information
  2. Standard of Integrity, Probity and Trustworthiness
    • Outcome: The court held that the Respondent's conduct fell below the required standards of integrity, probity, and trustworthiness required of an advocate and solicitor.
    • Category: Substantive

8. Remedies Sought

  1. Order for punishment under s 83(1) of the Legal Profession Act
  2. Striking off from the roll of advocates and solicitors

9. Cause of Actions

  • Professional Misconduct
  • Breach of Legal Profession Act
  • Breach of Legal Profession (Professional Conduct) Rules
  • Breach of Legal Profession (Solicitors’ Accounts) Rules

10. Practice Areas

  • Disciplinary Proceedings
  • Professional Responsibility

11. Industries

  • Legal Services

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
The Law Society of Singapore v Ng Bock Hoh DixonDisciplinary TribunalYes[2011] SGDT 7SingaporeThe judgment refers to the findings of the Disciplinary Tribunal (DT) which found the Respondent liable for three charges.
Law Society of Singapore v Ng Bock Hoh DixonCourt of Three JudgesYes[2010] 2 SLR 1000SingaporeCited as the 'False Judgment Disciplinary Proceedings', where the Respondent was suspended for preparing false court judgments. This prior disciplinary offense is considered an aggravating factor in the current proceedings.
Law Society of Singapore v Nor'ain bte Abu Bakar and othersCourt of AppealYes[2009] 1 SLR(R) 753SingaporeCited for the definition of 'grossly improper conduct' under s 83(2)(b) of the Act, stating that an intention to deceive is not required for a finding of liability.
Law Society of Singapore v Ng Chee SingHigh CourtYes[2000] 1 SLR(R) 466SingaporeCited to define 'misconduct unbefitting an advocate and solicitor' under s 83(2)(h) of the Act as a 'catch-all provision' applicable to conduct in the advocate and solicitor’s personal capacity.
Law Society of Singapore v Lim Cheong PengCourt of Three JudgesYes[2006] 4 SLR(R) 360SingaporeCited for the principle that the court of three Judges will not interfere with findings of fact by a disciplinary tribunal unless the conclusions are 'clearly against the weight of evidence'.
Bolton v Law SocietyEnglish Court of AppealYes[1994] 1 WLR 512England and WalesCited for the principle that an advocate and solicitor may be struck off even where dishonesty is not shown if he is 'shown to have fallen below the required standards of integrity, probity and trustworthiness'.
Law Society of Singapore v Ravindra SamuelCourt of AppealYes[1999] 1 SLR(R) 266SingaporeReference made to the decision of this court in Law Society of Singapore v Ravindra Samuel [1999] 1 SLR(R) 266 (“Ravindra Samuel”) at [14]-[15].
Law Society of Singapore v Tay Eng Kwee EdwinHigh CourtYes[2007] 4 SLR(R) 171SingaporeCited for the court's remarks on the importance of proper maintenance of clients’ accounts.
Law Society of Singapore v Low Yong SenCourt of AppealYes[2009] 1 SLR(R) 802SingaporeCited for the principle that a prior disciplinary offence is a significant aggravating factor in determining the appropriate sanction.
Public Prosecutor v Boon Kiah KinHigh CourtYes[1993] 2 SLR(R) 26SingaporeCited in the context of criminal law, regarding the relevance of prior offenses when sentencing an accused person.

13. Applicable Rules

Rule Name
r 12 of the Legal Profession (Professional Conduct) Rules (Cap 161, R 1, 2000 Rev Ed)
r 3 of the Legal Profession (Solicitors’ Accounts) Rules (Cap 161, R 8, 1999 Rev Ed)
r 4(2) of the Legal Profession (Accountant’s Report) Rules (Cap 161, R 10, 1999 Rev Ed)

14. Applicable Statutes

Statute NameJurisdiction
Legal Profession Act (Cap 161, 2009 Rev Ed)Singapore
s 83(1) of the Legal Profession Act (Cap 161, 2009 Rev Ed)Singapore
s 83(2) of the Legal Profession Act (Cap 161, 2009 Rev Ed)Singapore
s 83(2)(b) of the Legal Profession Act (Cap 161, 2009 Rev Ed)Singapore
s 83(2)(h) of the Legal Profession Act (Cap 161, 2009 Rev Ed)Singapore
s 98(1) of the Legal Profession ActSingapore
s 98(8) of the Legal Profession ActSingapore

15. Key Terms and Keywords

15.1 Key Terms

  • False Bill
  • Stakeholding Agreement
  • Professional Misconduct
  • Disciplinary Tribunal
  • Integrity
  • Probity
  • Trustworthiness
  • Accountant's Report
  • Party Political Donation
  • Client Account

15.2 Keywords

  • Law Society
  • Ng Bock Hoh Dixon
  • Disciplinary Action
  • False Bill
  • Professional Misconduct
  • Singapore High Court
  • Legal Profession Act
  • Integrity
  • Probity
  • Trustworthiness

17. Areas of Law

Area NameRelevance Score
Legal Ethics and Professional Responsibility95
Legal Ethics90
Professional Conduct Rules85
Professional Ethics80
Disciplinary Proceedings (Lawyers)75
Duty of Candour70
Breach of Solicitors' Accounts Rules60
Breach of Fiduciary Duty50
Duty of fidelity45
Breach of Court Order40

16. Subjects

  • Legal Profession
  • Professional Ethics
  • Disciplinary Proceedings