PP v Yeo Ek Boon: Sentencing for Voluntarily Causing Hurt to a Police Officer
The Public Prosecutor appealed against the District Court's sentence of one week's imprisonment imposed on Yeo Ek Boon, Jeffrey, for voluntarily causing hurt to a police officer under Section 332 of the Penal Code. The High Court, comprising Sundaresh Menon CJ, Tay Yong Kwang JA, and See Kee Oon J, allowed the appeal and increased the sentence to ten weeks' imprisonment, setting out a framework to guide sentencing in such cases. The incident occurred on 16 April 2016, when Yeo, while intoxicated, slapped Sergeant Ong Jiong Yang Andre. The court emphasized the need for general deterrence and the protection of police officers.
1. Case Overview
1.1 Court
High Court of the Republic of Singapore1.2 Outcome
Appeal Allowed
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal against sentence for voluntarily causing hurt to a police officer. The court increased the sentence to ten weeks' imprisonment.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Public Prosecutor | Appellant, Applicant | Government Agency | Appeal Allowed | Won | Sarah Shi of Attorney-General’s Chambers Tan Wen Hsien of Attorney-General’s Chambers Hri Kumar Nair SC of Attorney-General’s Chambers Randeep Singh of Attorney-General’s Chambers |
| Yeo Ek Boon, Jeffrey | Respondent | Individual | Sentence Increased | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Sundaresh Menon | Chief Justice | No |
| Tay Yong Kwang | Judge of Appeal | Yes |
| See Kee Oon | Judge | No |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Sarah Shi | Attorney-General’s Chambers |
| Tan Wen Hsien | Attorney-General’s Chambers |
| Hri Kumar Nair SC | Attorney-General’s Chambers |
| Randeep Singh | Attorney-General’s Chambers |
| Lim Ghim Siew Henry | G S Lim & Partners |
4. Facts
- The respondent pleaded guilty to voluntarily causing hurt to a police officer.
- The incident occurred at Balmoral Plaza at about 3.41 a.m. on 16 April 2016.
- The respondent was intoxicated and lying on a grass patch when approached by police officers.
- The respondent directed vulgarities at the police officers.
- The respondent slapped Sergeant Ong's left cheek once.
- Sergeant Ong sustained tenderness over his left cheek and abrasion over the left shin.
- The District Judge sentenced the respondent to one week's imprisonment.
5. Formal Citations
- Public Prosecutor v Yeo Ek Boon, Jeffrey and another matter, , [2017] SGHC 306
6. Timeline
| Date | Event |
|---|---|
| Respondent and friends went drinking at a club. | |
| Police received a call about a drunkard at Balmoral Plaza. | |
| Police located the respondent lying on a grass patch. | |
| Respondent slapped Sergeant Ong's left cheek. | |
| High Court convened to hear the appeal. | |
| Appeal allowed and sentence increased to ten weeks' imprisonment. |
7. Legal Issues
- Sentencing for Voluntarily Causing Hurt to a Public Servant
- Outcome: The court established a three-band sentencing framework for offences under Section 332 of the Penal Code involving police officers and public servants performing duties akin to police duties.
- Category: Substantive
- Sub-Issues:
- Appropriateness of custodial sentence
- Factors influencing the length of imprisonment
- General deterrence
- Retribution
- Related Cases:
- [2013] SGDC 327
- [2009] 1 SLR(R) 115
- Appellate Intervention in Sentencing
- Outcome: The court found that the original sentence of one week's imprisonment was manifestly inadequate and intervened to increase the sentence.
- Category: Procedural
- Sub-Issues:
- Manifest inadequacy of sentence
- Error in principle
8. Remedies Sought
- Increased Sentence
9. Cause of Actions
- Voluntarily Causing Hurt to a Public Servant
10. Practice Areas
- Criminal Law
- Sentencing Guidelines
11. Industries
- No industries specified
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Public Prosecutor v Ramizah Banu bte Abdul Rahman | District Court | Yes | [2013] SGDC 327 | Singapore | Cited for the sentencing range for cases involving police and law enforcement officers. |
| Wong Hoi Len v Public Prosecutor | High Court | Yes | [2009] 1 SLR(R) 115 | Singapore | Cited as an example of a benchmark sentence being set for offences against public transport workers. |
| Public Prosecutor v Koh Thiam Huat | High Court | Yes | [2017] 4 SLR 1099 | Singapore | Cited for the definition of harm and culpability in sentencing. |
| Public Prosecutor v Koh Keng Hong | District Court | Yes | [2015] SGDC 341 | Singapore | Cited as an illustration of an offence falling within Category 1 of the sentencing framework. |
| Public Prosecutor v Ho Eng Huat | District Court | Yes | [2016] SGDC 105 | Singapore | Cited as an illustration of an offence falling within Category 1 of the sentencing framework. |
| Public Prosecutor v Alfian Bin Abdullah | District Court | Yes | [2015] SGDC 111 | Singapore | Cited as an illustration of an offence falling within Category 1 of the sentencing framework. |
| Public Prosecutor v Alfian Bin Abdullah | High Court | Yes | (MA 9053/2015/01) | Singapore | Cited as an illustration of an offence falling within Category 1 of the sentencing framework. |
| Public Prosecutor v Soon Nyet Chin | District Court | Yes | [2014] SGDC 269 | Singapore | Cited as an example where a fine was imposed due to the offender's mental disorder. |
| Public Prosecutor v Dernny bin Zainalabiden | District Court | Yes | [2010] SGDC 180 | Singapore | Cited as an example of an offence falling within Category 2 of the sentencing framework. |
| R v Ramazan Gungor | England and Wales Court of Appeal (Criminal Division) | Yes | [2015] EWCA Crim 877 | England and Wales | Cited as a foreign case that would come within the Category 2 sentencing band. |
| R v Darius Ziemelies | England and Wales Court of Appeal (Criminal Division) | Yes | [2015] EWCA Crim 1220 | England and Wales | Cited as another foreign case that would come within the Category 2 sentencing band. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Penal Code (Cap 224, 2008 Rev Ed) | Singapore |
| Section 332 of the Penal Code | Singapore |
| Section 319 of the Penal Code | Singapore |
| Section 39 of the Penal Code | Singapore |
| Sections 85 and 86 of the Penal Code | Singapore |
| Section 323 of the Penal Code | Singapore |
| Section 333 of the Penal Code | Singapore |
| Police Force Act (Cap 235, 2006 Rev Ed) | Singapore |
| Section 4 of the Police Force Act (Cap 235, 2006 Rev Ed) | Singapore |
| Section 21 of the Penal Code | Singapore |
| Section 92(5) of the PFA | Singapore |
| Section 64 of the PFA | Singapore |
| Section 65 of the PFA | Singapore |
| Sections 66 to s 68 PFA | Singapore |
| s 511 of the Penal Code | Singapore |
| s 320 of the Penal Code | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Voluntarily causing hurt
- Public servant
- Police officer
- Sentencing framework
- General deterrence
- Harm
- Culpability
- Sentencing bands
- Prospective overruling
15.2 Keywords
- Voluntarily causing hurt
- Public servant
- Police officer
- Sentencing
- Singapore
- Criminal law
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Sentencing | 95 |
| Criminal Law | 90 |
| Criminal Procedure | 90 |
| Voluntarily Causing Hurt | 80 |
| Administrative Law | 10 |
16. Subjects
- Criminal Law
- Sentencing
- Criminal Procedure