Public Prosecutor v Liew Yong Liang: Hinderance of NEA Officers under Environmental Public Health Act

In Public Prosecutor v Liew Yong Liang, the High Court of Singapore heard an appeal against the Magistrate Court's decision to acquit Liew Yong Liang of a charge under s 82(1)(a) of the Environmental Public Health Act (EPHA). The charge alleged that Liew hindered NEA officers by refusing to provide his personal particulars. Chua Lee Ming J allowed the appeal, set aside the acquittal, convicted Liew, and ordered him to pay a fine of $1,000, finding that Liew's refusal did hinder the NEA officers in performing their duties.

1. Case Overview

1.1 Court

High Court of the Republic of Singapore

1.2 Outcome

Appeal Allowed

1.3 Case Type

Criminal

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

The High Court allowed the appeal, convicting Liew Yong Liang for hindering NEA officers by refusing to provide personal particulars, violating the Environmental Public Health Act.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Public ProsecutorAppellantGovernment AgencyAppeal AllowedWon
Charis Low of Attorney-General’s Chambers
Liew Yong LiangRespondentIndividualConvicted and finedLost

3. Judges

Judge NameTitleDelivered Judgment
Chua Lee MingJudgeYes

4. Counsels

Counsel NameOrganization
Charis LowAttorney-General’s Chambers

4. Facts

  1. Respondent threw a cigarette butt in a public place.
  2. NEA officers identified themselves and informed the respondent of the littering offence.
  3. Respondent refused to provide his personal particulars to the NEA officers.
  4. Police were called to the scene.
  5. Respondent eventually provided his particulars to the NEA officers after police intervention.
  6. The District Judge found that Rajendran had shown his authorisation card to the respondent.
  7. The respondent was a Foodpanda rider at the time of the incident.

5. Formal Citations

  1. Public Prosecutor v Liew Yong Liang, Magistrate’s Appeal No 11 of 2019, [2020] SGHC 30

6. Timeline

DateEvent
Respondent threw a cigarette butt on the floor.
NEA officers stopped the respondent and requested his particulars.
Police arrived at the scene.
Hearing date
Judgment date

7. Legal Issues

  1. Hinderance of Public Officer
    • Outcome: The court held that the respondent's refusal to provide his particulars hindered the NEA officers in the performance of their duties.
    • Category: Substantive
    • Sub-Issues:
      • Refusal to provide personal particulars
      • Undue delay to enforcement action
    • Related Cases:
      • [1999] 1 SLR(R) 996
      • [1996] 2 SLR(R) 858
  2. Mens Rea
    • Outcome: The court found that the respondent had the requisite mens rea to hinder the NEA officers.
    • Category: Substantive
    • Related Cases:
      • [1999] 1 SLR(R) 996

8. Remedies Sought

  1. Fine

9. Cause of Actions

  • Violation of s 82(1)(a) of the Environmental Public Health Act

10. Practice Areas

  • Criminal Litigation
  • Environmental Regulation

11. Industries

  • Food Delivery

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Zainal bin Kuning v Chan Sin Mian MichaelHigh CourtYes[1996] 2 SLR(R) 858SingaporeCited for the definition of 'arrest' as compelling someone to accompany an officer without physical restraint.
Foo Siang Wah Frederick v Public ProsecutorHigh CourtYes[1999] 1 SLR(R) 996SingaporeCited for the definition of 'hinder' as causing appreciable interference with an officer's duty.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Environmental Public Health Act (Cap 95, 2002 Rev Ed) s 82(1)(a)Singapore
Environmental Public Health Act (Cap 95, 2002 Rev Ed) s 103Singapore
Environmental Public Health Act (Cap 95, 2002 Rev Ed) s 21Singapore
Environmental Public Health Act (Cap 95, 2002 Rev Ed) s 86(1)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Environmental Public Health Act
  • NEA officers
  • Littering
  • Hinderance
  • Personal particulars
  • Authorisation card
  • Enforcement action

15.2 Keywords

  • Environmental Public Health Act
  • Littering
  • NEA
  • Hinderance
  • Singapore
  • Criminal Law

17. Areas of Law

Area NameRelevance Score
Environmental Public Health Act95
Statutory offences90
Criminal Law75
Administrative Law60

16. Subjects

  • Criminal Law
  • Environmental Law
  • Statutory Interpretation