Law Society of Singapore v Yeo Siew Chye Troy: Disciplinary Proceedings for Failure to Supervise Employee Leading to Misappropriation

The Law Society of Singapore brought an action against Yeo Siew Chye Troy, an advocate and solicitor, for failing to properly supervise his employee, Sim Tee Peng, who misappropriated $848,335.09 from 17 clients. The Court of Three Judges found Yeo guilty of grossly improper conduct and suspended him for four years, emphasizing the need to uphold public confidence in the legal profession.

1. Case Overview

1.1 Court

Court of Three Judges of the republic of singapore

1.2 Outcome

Suspension of four years imposed on the respondent.

1.3 Case Type

Regulatory

1.4 Judgment Type

Ex Tempore Judgment

1.5 Jurisdiction

Singapore

1.6 Description

The Law Society brought disciplinary proceedings against Yeo Siew Chye Troy for failing to properly supervise an employee who misappropriated client funds. The Court of Three Judges suspended Yeo for four years.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Law Society of SingaporeApplicantStatutory BoardJudgment for ApplicantWon
Yeo Siew Chye TroyRespondentIndividualSuspension of four yearsLost

3. Judges

Judge NameTitleDelivered Judgment
Sundaresh MenonChief JusticeYes
Andrew Phang Boon LeongJudge of AppealNo
Woo Bih LiJudgeNo

4. Counsels

Counsel NameOrganization
Vergis S AbrahamProvidence Law Asia LLC
Bestlyn LooProvidence Law Asia LLC
Kenneth Tan SCKenneth Tan Partnership

4. Facts

  1. The respondent, an advocate and solicitor, failed to properly supervise his employee, Sim Tee Peng.
  2. Sim misappropriated $848,335.09 from 17 clients between June 2011 and March 2012.
  3. The respondent allowed conveyancing moneys to be paid into the firm’s office account.
  4. Sim produced forged stamp duty certificates to mislead the firm.
  5. The respondent was unaware of Sim's fraudulent activities for an extended period.
  6. The respondent went into a new area of practice with a complete lack of care.

5. Formal Citations

    6. Timeline

    DateEvent
    Respondent admitted as an advocate and solicitor of the Supreme Court of Singapore
    Respondent became sole proprietor and sole director of Troy Yeo & Co
    Respondent met Sim Tee Peng
    Respondent permitted Sim to interact directly with firm's conveyancing clients
    Conveyancing moneys paid into firm's office account
    Conveyancing moneys paid into firm's office account
    Inland Revenue Authority of Singapore raided the firm’s office premises
    Respondent permitted Sim to interact directly with firm's conveyancing clients
    Judgment delivered
    Suspension to take effect

    7. Legal Issues

    1. Failure to Exercise Proper Supervision
      • Outcome: The court found that the respondent failed to exercise proper supervision over his employee, constituting a gross breach of duty.
      • Category: Substantive
      • Sub-Issues:
        • Inadequate system of periodic checks
        • Dereliction of duty
    2. Breach of Solicitors' Accounts Rules
      • Outcome: The court found that the respondent breached the relevant rules of the Legal Profession (Solicitors’ Accounts) Rules and the Conveyancing and Law of Property (Conveyancing) Rules 2011.
      • Category: Substantive
    3. Improper Accounting Practices
      • Outcome: The court found that the respondent did not keep proper accounts, breaching r 11(1) of the LPSAR.
      • Category: Substantive

    8. Remedies Sought

    1. Disciplinary Sanctions

    9. Cause of Actions

    • Breach of Legal Profession (Professional Conduct) Rules
    • Breach of Legal Profession (Solicitors’ Accounts) Rules
    • Grossly Improper Conduct

    10. Practice Areas

    • Professional Responsibility
    • Regulatory Compliance

    11. Industries

    • Legal Services

    12. Cited Cases

    Case NameCourtAffirmedCitationJurisdictionSignificance
    Law Society of Singapore v Ravi s/o MadasamySingapore High CourtYes[2016] 5 SLR 1141SingaporeCited for the principle that the paramount considerations in determining sanctions are upholding public confidence and protecting the public, and that personal culpability is not as important.
    Law Society of Singapore v Chia Choon YangSingapore High CourtYes[2018] 5 SLR 1068SingaporeCited for the principle that the paramount considerations in determining sanctions are upholding public confidence and protecting the public, and that personal culpability is not as important.
    Law Society of Singapore v Ezekiel Peter LatimerSingapore High CourtYes[2019] SGHC 92SingaporeCited for the principle that the paramount considerations in determining sanctions are upholding public confidence and protecting the public, and that personal culpability is not as important.

    13. Applicable Rules

    Rule Name
    Conveyancing and Law of Property (Conveyancing) Rules 2011 (S 391/2011)

    14. Applicable Statutes

    Statute NameJurisdiction
    Legal Profession Act (Cap 161, 2009 Rev Ed)Singapore
    Legal Profession (Professional Conduct) Rules (Cap 161, R 1, 2010 Rev Ed)Singapore
    Legal Profession (Solicitors’ Accounts) Rules (Cap 161, R 8, 1999 Rev Ed)Singapore

    15. Key Terms and Keywords

    15.1 Key Terms

    • Disciplinary Tribunal
    • Misappropriation
    • Conveyancing moneys
    • Professional misconduct
    • Breach of duty
    • Lack of supervision
    • Forged stamp duty certificates
    • Solicitors' Accounts Rules

    15.2 Keywords

    • Disciplinary proceedings
    • Legal profession
    • Solicitor
    • Misconduct
    • Supervision
    • Conveyancing
    • Singapore

    17. Areas of Law

    Area NameRelevance Score
    Disciplinary Proceedings95
    Legal Profession Act90
    Grossly Improper Conduct90
    Failure to supervise90
    Professional Misconduct85
    Solicitors' Accounts Rules80
    Breach of Duty70
    Contract Law5
    Company Law5
    Standard form contract5

    16. Subjects

    • Professional Discipline
    • Legal Ethics
    • Conveyancing
    • Solicitors' Accounts