Teo Jun Kiat, Evan v Attorney-General: Part-Call Application & Legal Profession Act Discretion
In Re Teo Jun Kiat, Evan (alias Zhang Junjie), the High Court of Singapore heard an application by Mr. Nicholas Jeyaraj s/o Narayanan on behalf of his practice trainee, Mr. Teo Jun Kiat, Evan (Zhang Junjie), for limited audience before the courts under s 32(3) of the Legal Profession Act. The Attorney-General and the Law Society of Singapore objected, arguing that completion of Part B of the Singapore Bar Examinations should be a prerequisite. The court, presided over by Edmund Leow JC, dismissed the application, holding that while not an express requirement, the Act assumes practice trainees would have completed the necessary courses and examinations before being part-called.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Application Dismissed
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
The High Court considered whether to allow a practice trainee to be part-called before completing Part B of the Singapore Bar Examinations, ultimately dismissing the application.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Teo Jun Kiat, Evan (alias Zhang Junjie) | Applicant | Individual | Application Dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Edmund Leow | Judicial Commissioner | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Nicholas Jeyaraj s/o Narayanan | Nicholas & Tan Partnership LLP |
4. Facts
- Mr. Teo applied for limited audience before the courts before completing Part B of the Singapore Bar Examinations.
- The Law Society and the Attorney-General objected to the application.
- Mr. Teo completed his Juris Doctor degree from the University of Sydney.
- Mr. Teo had completed his relevant legal training.
- Mr. Teo commenced his practice training contract with the Firm.
- Mr. Teo passed Part A Examinations.
5. Formal Citations
- Re Teo Jun Kiat, Evan (alias Zhang Junjie), Admission of Advocates and Solicitors No 197 of 2015 (HC/Summons No 1927 of 2015), [2015] SGHC 274
6. Timeline
| Date | Event |
|---|---|
| Mr. Teo completed final examinations of Juris Doctor degree from the University of Sydney | |
| Mr. Teo commenced relevant legal training with Selvam LLC | |
| Mr. Teo commenced practice training contract with the Firm | |
| National University of Singapore certified Mr. Teo passed Part A Examinations | |
| Mr. Teo’s name entered into the register of qualified persons maintained by SILE | |
| SILE approved the manner in which Mr Teo was to serve his practice training period | |
| Judgment issued |
7. Legal Issues
- Part-Call Application
- Outcome: The court dismissed the application, finding that the applicant had not demonstrated sufficient knowledge and experience to compensate for not completing Part B of the Singapore Bar Examinations.
- Category: Procedural
8. Remedies Sought
- Order permitting limited audience before the courts
9. Cause of Actions
- No cause of actions
10. Practice Areas
- Admission to the Bar
- Advocacy
11. Industries
- Legal Services
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Tan Yock Lin, The Law of Advocates and Solicitors in Singapore and West Malaysia | N/A | Yes | Tan Yock Lin, The Law of Advocates and Solicitors in Singapore and West Malaysia (Butterworths Asia, 2nd Ed, 1998) | Singapore | Cited for the principle that the concession of limited right of audience to pupils must not lead to a miscarriage of justice. |
13. Applicable Rules
| Rule Name |
|---|
| Legal Profession (Admission) Rules 2011 (Cap 161, S 244/2011) |
| r 16(1) of the Legal Profession (Admission) Rules 2011 |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Legal Profession Act (Cap 161, 2009 Rev Ed) | Singapore |
| s 32(3) of the Legal Profession Act | Singapore |
| s 13(1) of the Legal Profession Act | Singapore |
| Legal Profession (Amendment) Act 2011 (Act 8 of 2011) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Part-call application
- Practice trainee
- Legal Profession Act
- Part B Examinations
- Relevant legal training
15.2 Keywords
- Part-call
- Legal Profession Act
- Singapore
- Advocate
- Solicitor
- Admission
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Admission to the Bar | 90 |
| Legal Profession Act | 90 |
| Criminal Procedure | 50 |
| Civil Procedure | 50 |
| Evidence Law | 30 |
16. Subjects
- Civil Procedure
- Legal Education
- Admission to the Bar