PP v Low Chuan Woo: Culpable Homicide, Women's Charter Offences & Bar Fine Arrangement
In Public Prosecutor v Low Chuan Woo, the High Court of Singapore heard the case against Low Chuan Woo, who pleaded guilty to culpable homicide not amounting to murder under Section 304(a) of the Penal Code, and several offences under the Women's Charter, including living on the earnings of prostitutes under Section 146(1) and managing a place of assignation under Section 147(1). The charges arose from an incident at Low Chuan Woo's pub, Ramesses Entertainment, where he stabbed a patron, Mohamed Iskandar Bin Ishak, during an altercation, and from his involvement in a 'bar fine' arrangement with female performing artistes. The court sentenced Low Chuan Woo to 4 years' imprisonment for the culpable homicide charge and 4 months' imprisonment for each of the three Women's Charter offences, with two of the latter to run consecutively, resulting in a total sentence of 4 years and 8 months.
1. Case Overview
1.1 Court
High Court1.2 Outcome
The accused was sentenced to 4 years' imprisonment for culpable homicide and 4 months' imprisonment for each of the three Women's Charter offences, with two of the latter to run consecutively.
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Low Chuan Woo pleaded guilty to culpable homicide and Women's Charter offences, including living on the earnings of prostitutes and managing a place of assignation.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Public Prosecutor | Prosecution | Government Agency | Judgment for Prosecution | Won | Anamika Bagchi, Shahla Iqbal |
| Low Chuan Woo | Defendant | Individual | Convicted and Sentenced | Lost | Ram Goswami, Cheng Kim Kuan |
| Mohamed Iskandar Bin Ishak | Other | Individual |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Tay Yong Kwang | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Anamika Bagchi | DPPs |
| Shahla Iqbal | DPPs |
| Ram Goswami | Ram Goswami |
| Cheng Kim Kuan | K.K. Cheng & Co |
4. Facts
- The accused stabbed the deceased twice during an altercation at the accused's pub.
- The deceased was heavily intoxicated and had assaulted the accused and his staff.
- The accused retrieved a knife from the bar counter before confronting the deceased.
- The deceased's pre-existing heart condition contributed to his death.
- The accused had a 'bar fine' arrangement with female performing artistes at his pub.
- The accused received a cut of 50% from the 'bar fine' paid by customers to the performing artistes for sexual services.
5. Formal Citations
- Public Prosecutor v Low Chuan Woo, Criminal Case No 21 of 2014, [2014] SGHC 118
6. Timeline
| Date | Event |
|---|---|
| Accused was born | |
| Accused was fined for using abusive language | |
| Accused opened Ramesses Entertainment | |
| Accused was fined for affray and mischief | |
| Accused managed a place of assignation | |
| Accused knowingly lived on earnings of prostitution | |
| Accused knowingly lived on earnings of prostitution | |
| Accused knowingly lived on earnings of prostitution | |
| Accused knowingly lived on earnings of prostitution | |
| Accused knowingly lived on earnings of prostitution | |
| Accused managed a place of assignation | |
| Accused knowingly lived on earnings of prostitution | |
| Accused caused the death of Mohamed Iskandar Bin Ishak by stabbing him | |
| Mohamed Iskandar Bin Ishak pronounced dead at Changi General Hospital | |
| Accused was arrested | |
| Judgment Date |
7. Legal Issues
- Culpable Homicide
- Outcome: The court found the accused guilty of culpable homicide not amounting to murder.
- Category: Substantive
- Living on Earnings of Prostitution
- Outcome: The court found the accused guilty of living on the earnings of prostitution.
- Category: Substantive
- Managing a Place of Assignation
- Outcome: The court found the accused guilty of managing a place of assignation.
- Category: Substantive
8. Remedies Sought
- Imprisonment
- Fine
- Caning
9. Cause of Actions
- Culpable Homicide
- Living on Earnings of Prostitution
- Managing a Place of Assignation
10. Practice Areas
- Criminal Litigation
11. Industries
- Entertainment
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| PP v Tan Kei Loon Allan | Court of Appeal | Yes | [1998] 3 SLR(R) 679 | Singapore | Cited for the principle that sentencing for culpable homicide should be determined on the facts of each case. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Section 304(a) of the Penal Code, Chapter 224 | Singapore |
| Section 146(1) of the Women's Charter, Chapter 353 | Singapore |
| Section 147(1) of the Women's Charter, Chapter 353 | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Culpable Homicide
- Women's Charter
- Bar Fine
- Place of Assignation
- Performing Artistes
- Intoxication
- Self-Defense
- Provocation
15.2 Keywords
- Culpable Homicide
- Women's Charter
- Prostitution
- Singapore
- Criminal Law
- Pub
- Stabbing
- Intoxication
- Bar Fine
16. Subjects
- Criminal Law
- Sentencing
- Prostitution
- Homicide
17. Areas of Law
- Criminal Law
- Culpable Homicide
- Women's Charter
- Prostitution Offences