Daryati v Public Prosecutor: Appeal Against Murder Conviction Based on Diminished Responsibility

Daryati, an Indonesian domestic helper, appealed against her conviction for murder under section 300(c) of the Penal Code. The Court of Appeal dismissed the appeal, finding that the defense of diminished responsibility was not proven. The court rejected the appellant's claim of suffering from persistent depressive disorder with intermittent depressive disorder at the time of the murder, affirming the original life imprisonment sentence.

1. Case Overview

1.1 Court

Court of Appeal of the Republic of Singapore

1.2 Outcome

Appeal Dismissed

1.3 Case Type

Criminal

1.4 Judgment Type

Ex Tempore Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Appeal against murder conviction. The court affirmed the conviction, rejecting the defense of diminished responsibility due to lack of evidence.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Public ProsecutorRespondentGovernment AgencyConviction AffirmedWon
Lim Shin Hui of Attorney-General’s Chambers
Wong Kok Weng of Attorney-General’s Chambers
Phoebe Tan Hern Hwei of Attorney-General’s Chambers
DaryatiAppellantIndividualAppeal DismissedLost

3. Judges

Judge NameTitleDelivered Judgment
Andrew Phang Boon LeongJustice of the Court of AppealYes
Steven ChongJustice of the Court of AppealNo
Chao Hick TinSenior JudgeNo

4. Counsels

Counsel NameOrganization
Lim Shin HuiAttorney-General’s Chambers
Wong Kok WengAttorney-General’s Chambers
Phoebe Tan Hern HweiAttorney-General’s Chambers
Koh Weijin LeonN.S. Kang
Elsie Lim YanN.S. Kang

4. Facts

  1. The appellant, an Indonesian national, was convicted of murder under s 300(c) of the Penal Code.
  2. The appellant worked as a domestic helper for the deceased and her family.
  3. The appellant claimed to be suffering from persistent depressive disorder with intermittent depressive disorder at the time of the murder.
  4. The appellant's defense was diminished responsibility under Exception 7 to s 300 of the Penal Code.
  5. The trial Judge rejected the appellant's defense.
  6. The appellant appealed against her conviction.

5. Formal Citations

  1. Daryati v Public Prosecutor, Criminal Appeal No 14 of 2021, [2022] SGCA 30
  2. Public Prosecutor v Daryati, , [2021] SGHC 135

6. Timeline

DateEvent
Criminal Appeal No 14 of 2021 filed
Trial Judge’s decision at [2021] SGHC 135
Court of Appeal delivered judgment

7. Legal Issues

  1. Diminished Responsibility
    • Outcome: The court found that the appellant was not entitled to the defence of diminished responsibility.
    • Category: Substantive
    • Sub-Issues:
      • Abnormality of mind
      • Causation of abnormality of mind
      • Substantial impairment of mental responsibility
    • Related Cases:
      • [2019] 2 SLR 216
      • [1960] 2 QB 396

8. Remedies Sought

  1. Appeal against conviction

9. Cause of Actions

  • Murder

10. Practice Areas

  • Criminal Law
  • Appeals

11. Industries

  • No industries specified

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Nagaenthran a/l K Dharmalingam v Public Prosecutor and another appealCourt of AppealYes[2019] 2 SLR 216SingaporeCited for the elements of the defence of diminished responsibility.
R v ByrneEnglish Court of AppealYes[1960] 2 QB 396England and WalesCited for the test of abnormality of mind.
Public Prosecutor v DaryatiHigh CourtYes[2021] SGHC 135SingaporeCited for the undisputed background facts and the trial Judge’s decision.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Penal Code (Cap 224, 2008 Rev Ed) s 300(c)Singapore
Penal Code (Cap 224, 2008 Rev Ed) Exception 7 to s 300Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Diminished responsibility
  • Persistent depressive disorder
  • Abnormality of mind
  • Functional impairment
  • Murder
  • Penal Code

15.2 Keywords

  • murder
  • diminished responsibility
  • criminal law
  • singapore
  • appeal

17. Areas of Law

Area NameRelevance Score
Criminal Law95
Diminished Responsibility95
Murder90
Evidence60
Psychiatry50
Criminal Appeals40
Civil Procedure10
Witnesses5
Sentencing5

16. Subjects

  • Criminal Law
  • Diminished Responsibility
  • Murder