Re Tay Quan Li Leon: Cheating in Bar Exams & Admission to the Bar

In the case of Re Tay Quan Li Leon, the High Court of Singapore addressed the application of Tay Quan Li Leon to be admitted as an Advocate and Solicitor of the Supreme Court. The Attorney-General objected to the application based on Leon's misconduct during the Singapore Bar examinations. Leon cheated during the examinations and initially made misleading statements to the Singapore Institute of Legal Education. The court allowed Leon to withdraw his application subject to certain undertakings, including a five-year ban on re-applying and compliance with any requirements to demonstrate his fitness for admission.

1. Case Overview

1.1 Court

General Division of the High Court

1.2 Outcome

Withdrawal Application allowed subject to conditions.

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Singapore High Court addresses a law graduate's cheating in bar exams and subsequent application for admission to the Bar. The court disallowed sealing of court papers.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Attorney-GeneralRespondentGovernment AgencyOtherNeutral
Jeyendran s/o Jeyapal of Attorney-General’s Chambers
Tongyi Tan of Attorney-General’s Chambers
Lam Xiu Ping Vanessa of Attorney-General’s Chambers
Law Society of SingaporeRespondentStatutory BoardOtherNeutral
Singapore Institute of Legal EducationRespondentStatutory BoardOtherNeutral
Chong Soon Yong Avery of Singapore Institute of Legal Education
Tay Quan Li LeonApplicantIndividualWithdrawal Application allowed subject to conditionsPartial

3. Judges

Judge NameTitleDelivered Judgment
Sundaresh MenonChief JusticeYes

4. Counsels

Counsel NameOrganization
Jeyendran s/o JeyapalAttorney-General’s Chambers
Tongyi TanAttorney-General’s Chambers
Lam Xiu Ping VanessaAttorney-General’s Chambers
Darryl Chew ZijieChia Wong Chambers LLC
Davis Tan Yong ChuanRajah & Tann Singapore LLP
Kenneth LimAllen & Gledhill LLP
Chong Soon Yong AverySingapore Institute of Legal Education
Luo Ling LingLuo Ling Ling LLC

4. Facts

  1. Tay Quan Li Leon cheated in the 2020 Part B Exams.
  2. Leon lied to the Dean of the Singapore Institute of Legal Education about the cheating incident.
  3. Leon made partial and selective disclosures in his Admission Application.
  4. The Student Disciplinary Committee found that Leon had acted fraudulently and dishonestly in his dealings with the SILE.
  5. Leon applied to withdraw his Admission Application.
  6. Leon sought a sealing and redaction order for the court papers.
  7. Professor Kua opined that the disclosure of Leon’s name “could” trigger a severe psychiatric reaction.

5. Formal Citations

  1. Re Tay Quan Li Leon, Admission of Advocates and Solicitors No 35 of 2022, [2022] SGHC 133

6. Timeline

DateEvent
2020 Part B Exams took place
2020 Part B Exams took place
Applicant met with the Dean of the SILE
Applicant replied to SILE
SILE informed the Applicant about the PDF files
Director of the Part B Course reported to the Student Disciplinary Committee
SDC gave notice to Leon
SILE issued a notice
Leon made the present Admission Application
Leon wrote to the SILE
Leon wrote to the SILE
First supporting affidavit filed
Leon filed his first supplementary affidavit
AG wrote to Leon
First Judgment issued
Leon wrote to the Stakeholders
Leon filed his second supplementary affidavit
Leon applied to withdraw his application for admission
Second Judgment released
Applicant sought a sealing and redaction order
Admission Application was scheduled to be heard
Judgment Date

7. Legal Issues

  1. Admission to the Bar
    • Outcome: The court found that the applicant was not a fit and proper person to be admitted to the Bar at this time due to cheating in the Part B Exams, providing a false account to the Dean of SILE, and making partial and selective disclosures in the Admission Application.
    • Category: Substantive
    • Sub-Issues:
      • Character and suitability of applicant
      • Honesty and integrity
  2. Sealing Order
    • Outcome: The court dismissed the Sealing Order Application, holding that the principle of open justice applied and that the applicant had not demonstrated sufficient grounds to justify a departure from this principle.
    • Category: Procedural
    • Sub-Issues:
      • Principle of open justice
      • Court's inherent powers

8. Remedies Sought

  1. Admission to the Bar
  2. Sealing Order
  3. Withdrawal of Application

9. Cause of Actions

  • No cause of actions

10. Practice Areas

  • Admission to the Bar
  • Inherent Powers

11. Industries

  • Legal Services

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Re CTA and other mattersHigh CourtYes[2022] SGHC 87SingaporeCited for the adjournment of Ms Kuek's application for 12 months and for the applications of each of the other five applicants to be adjourned for six months.
Re Monisha Devaraj and other mattersHigh CourtYes[2022] SGHC 93SingaporeCited for the rescinding of the sealing and redaction order.
Chua Yi Jin Colin v Public ProsecutorHigh CourtYes[2021] SGHC 290SingaporeCited for the principle of open justice.
Iskandar bin Rahmat v Law Society of SingaporeHigh CourtYes[2020] SGHC 40SingaporeCited for the role of the legal profession in upholding the justice system.
BBW v BBX and othersHigh CourtYes[2016] 5 SLR 755SingaporeCited for the court's inherent powers in granting a sealing and redaction order.
Miya Manik v Public Prosecutor and another matterHigh CourtYes[2021] 2 SLR 1169SingaporeCited for the criteria expected of a forensic psychiatric report.

13. Applicable Rules

Rule Name
Legal Profession (Admission) Rules 2011
Rules of Court

14. Applicable Statutes

Statute NameJurisdiction
Legal Profession Act 1966Singapore
Supreme Court of Judicature Act 1969Singapore
Criminal Procedure Code 2010Singapore
Children and Young Persons Act 1993Singapore
Family Justice Act 2014Singapore
Arbitration Act 2001Singapore
International Arbitration Act 1994Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Admission to the Bar
  • Sealing Order
  • Open Justice
  • Cheating
  • Character
  • Integrity
  • Rehabilitation
  • Student Disciplinary Committee
  • SILE Notice
  • Undertaking

15.2 Keywords

  • Admission to the Bar
  • Cheating
  • Legal Profession
  • Singapore
  • Ethics
  • Integrity
  • Sealing Order

17. Areas of Law

Area NameRelevance Score
Admission of Advocates and Solicitors95
Legal Profession Act90
Legal Ethics and Professional Responsibility85
Civil Procedure70
Sealing order60
Administrative Law30
Evidence Law20

16. Subjects

  • Legal Ethics
  • Civil Procedure
  • Professional Responsibility