Attorney-General v Ravi Madasamy: Contempt of Court under the Administration of Justice (Protection) Act
In Attorney-General v Ravi s/o Madasamy, the High Court of Singapore found Mr. Ravi s/o Madasamy liable for nine instances of contempt of court under the Administration of Justice (Protection) Act 2016. The Attorney-General brought two originating summonses, OS 21 and 22 of 2022. The court sentenced Mr. Ravi to a total of 21 days' imprisonment, with sentences for the Second and Sixth instances to run consecutively and the remaining sentences to run concurrently.
1. Case Overview
1.1 Court
General Division of the High Court1.2 Outcome
Sentenced to 21 days of imprisonment.
1.3 Case Type
Criminal
1.4 Judgment Type
Judgment
1.5 Jurisdiction
Singapore
1.6 Description
Ravi Madasamy was found liable for nine instances of contempt of court. The court sentenced him to 21 days of imprisonment.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Ravi s/o Madasamy | Respondent | Individual | Sentenced to imprisonment | Lost | |
| The Attorney-General | Applicant | Government Agency | Judgment for Applicant | Won | Wuan Kin Lek Nicholas of Attorney-General’s Chambers Chong Yong of Attorney-General’s Chambers Rimplejit Kaur of Attorney-General’s Chambers |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Hoo Sheau Peng | Judge | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Wuan Kin Lek Nicholas | Attorney-General’s Chambers |
| Chong Yong | Attorney-General’s Chambers |
| Rimplejit Kaur | Attorney-General’s Chambers |
4. Facts
- Mr. Ravi was found liable for nine instances of contempt under the Administration of Justice (Protection) Act 2016.
- The contemptuous acts included scandalising the court, interrupting court proceedings, and insulting a judge.
- Mr. Ravi was suffering from a hypomanic episode of bipolar disorder at the time of the contemptuous acts.
- Mr. Ravi was a senior lawyer at the time of the contemptuous acts.
- Mr. Ravi had a history of misconduct within the courtroom.
- Mr. Ravi did not display remorse for his actions.
- The court found that Mr. Ravi's bipolar disorder had a contributory link to his conduct but did not substantially impair his ability to exercise self-control.
5. Formal Citations
- Attorney-General v Ravi s/o Madasamy and another matter, , [2023] SGHC 321
6. Timeline
| Date | Event |
|---|---|
| Mr Ravi accused District Judge Chay Yuen Fatt of being biased. | |
| Mr Ravi intentionally interrupted District Judge Chay Yuen Fatt. | |
| Mr Ravi insulted District Judge Chay Yuen Fatt. | |
| Mr Ravi insulted District Judge Chay Yuen Fatt. | |
| Mr Ravi accused Justice Audrey Lim of being biased. | |
| Mr Ravi intentionally interrupted Justice Audrey Lim. | |
| Mr Ravi made allegations impugning the propriety of the court. | |
| Mr Ravi applied for Justice Audrey Lim to disqualify herself. | |
| Mr Ravi caused his paralegal to send an email to the Supreme Court Registry without instructions. | |
| The respondent, Mr Ravi s/o Madasamy, was found liable for nine instances of contempt. | |
| Sentencing hearing. | |
| Judgment reserved. |
7. Legal Issues
- Contempt of court
- Outcome: The court found Mr. Ravi liable for nine instances of contempt of court.
- Category: Substantive
- Sub-Issues:
- Scandalising the court
- Interruption of court proceedings
- Insulting a judge
- Obstructing the administration of justice
- Sentencing
- Outcome: The court sentenced Mr. Ravi to 21 days of imprisonment.
- Category: Procedural
- Sub-Issues:
- Mitigating factors
- Aggravating factors
- Custodial threshold
- Totality principle
- Mental disorder as a mitigating factor
- Outcome: The court found that Mr. Ravi's bipolar disorder had a contributory link to his conduct but did not substantially impair his ability to exercise self-control.
- Category: Substantive
- Sub-Issues:
- Impact on culpability
- Diminution of self-control
8. Remedies Sought
- Order of committal for contempt of court
9. Cause of Actions
- Contempt of Court
10. Practice Areas
- Criminal Litigation
11. Industries
- Legal Services
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Shadrake Alan v Attorney-General | Court of Appeal | Yes | [2011] 3 SLR 778 | Singapore | Cited for factors relevant to sentencing for scandalising contempt. |
| Wham Kwok Han Jolovan v Attorney-General and other appeals | Court of Appeal | Yes | [2020] 1 SLR 804 | Singapore | Cited to show that the factors in Shadrake Alan remain relevant under s 12(1)(a) of the AJPA. |
| You Xin v Public Prosecutor and another appeal | High Court | Yes | [2007] 4 SLR(R) 17 | Singapore | Cited for the court's approach to sentencing for contempt in the face of the court. |
| The Law Society of Singapore v Ravi s/o Madasamy | Disciplinary Tribunal | Yes | [2015] SGDT 5 | Singapore | Cited to compare Mr Ravi's mental condition at the time of a separate instance of impugned conduct. |
| Public Prosecutor v Chia Kee Chen and another appeal | Court of Appeal | Yes | [2018] 2 SLR 249 | Singapore | Cited for the principle that an offender's mental condition is relevant to sentencing if it lessens the offender's culpability. |
| Law Society of Singapore v Ravi Madasamy | Court of Three Judges | Yes | [2007] 2 SLR(R) 300 | Singapore | Cited as an example of Mr Ravi's history of misconduct within the courtroom. |
| The Law Society of Singapore v Ravi s/o Madasamy | Disciplinary Tribunal | Yes | [2012] SGDT 12 | Singapore | Cited as an example of Mr Ravi's history of misconduct within the courtroom. |
| The Law Society of Singapore v Ravi s/o Madasamy | Disciplinary Tribunal | Yes | [2020] SGDT 8 | Singapore | Cited as an example of Mr Ravi's history of misconduct within the courtroom. |
| Chee Siok Chin and another v Attorney-General | High Court | Yes | [2006] 4 SLR(R) 541 | Singapore | Cited as an example of Mr Ravi's history of misconduct within the courtroom. |
| Norasharee bin Gous v Public Prosecutor | Court of Appeal | Yes | [2021] 2 SLR 140 | Singapore | Cited as an example of Mr Ravi's history of misconduct within the courtroom. |
| Nagaenthran a/l K Dharmalingam v Attorney-General and another matter | Court of Appeal | Yes | [2022] 2 SLR 211 | Singapore | Cited as an example of Mr Ravi's history of misconduct within the courtroom. |
| Vasentha d/o Joseph v Public Prosecutor | High Court | Yes | [2015] 5 SLR 122 | Singapore | Cited for the proposition that a court ought not take into account offences in respect of which a person has not been found guilty. |
| Tan Gek Young v Public Prosecutor | High Court | Yes | [2017] 5 SLR 820 | Singapore | Cited for the principle that the court is entitled to take into account an offender's conviction in a disciplinary proceeding as a relevant antecedent if it is similar to the present offence. |
| Thong Sing Hock v Public Prosecutor | Court of Appeal | Yes | [2009] 3 SLR(R) 47 | Singapore | Cited for the principle that a lack of remorse may constitute an aggravating factor in sentencing. |
| Attorney-General v Chee Soon Juan | High Court | Yes | [2006] 2 SLR(R) 650 | Singapore | Cited to show that scandalising contempt made in open court is an aggravating factor. |
| Ong Wui Teck v Attorney-General | Court of Appeal | Yes | [2020] 1 SLR 855 | Singapore | Cited to show that scandalising contempt made in open court is an aggravating factor. |
| Au Wai Pang v Attorney-General | High Court | Yes | [2016] 1 SLR 992 | Singapore | Cited as a precedent for sentencing in scandalising contempt cases. |
| Balogh v St Albans Crown Court | Court of Appeal | Yes | [1975] QB 73 | England and Wales | Cited to define the extreme procedure that is exercised by a judge of his own motion only when it is urgent and imperative to act immediately. |
| Loh Der Ming Andrew v Law Society of Singapore | Court of Appeal | Yes | [2018] 3 SLR 837 | Singapore | Cited to show that an advocate and solicitor who acts in a manner contrary to the instructions of his client poses a serious threat to the public trust in the administration of justice. |
| Public Prosecutor v Raveen Balakrishnan | Court of Appeal | Yes | [2018] 5 SLR 799 | Singapore | Cited for the general principle that sentences of imprisonment for unrelated offences ought to be made to run consecutively. |
13. Applicable Rules
| Rule Name |
|---|
| Order 52 of the Rules of Court (Cap 322, R5, 2014 Rev Ed) |
| r 9(1)(a) of the Legal Profession (Professional Conduct) Rules 2015 |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Administration of Justice (Protection) Act 2016 | Singapore |
| Sections 3(1)(a), 3(1)(d), 3(1)(e), 10(1) and 10(2) of the Administration of Justice (Protection) Act 2016 (No 19 of 2016) | Singapore |
| s 12 of the AJPA | Singapore |
| Criminal Procedure Code (Cap 68, 2012 Rev Ed) | Singapore |
| s 339 of the Criminal Procedure Code (Cap 68, 2012 Rev Ed) | Singapore |
| Legal Profession Act (Cap 161, 2001 Rev Ed) | Singapore |
| s 83(2)(h) of the Legal Profession Act (Cap 161, 2001 Rev Ed) | Singapore |
| s 96 of the LPA | Singapore |
| s 5(1)(a) read with s 5(2) of the Misuse of Drugs Act (Cap 185, 2008 Rev Ed) | Singapore |
| s 377A of the Penal Code | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Contempt of court
- Scandalising contempt
- Hypomanic episode
- Bipolar disorder
- Mitigating factor
- Aggravating factor
- Custodial threshold
- Administration of justice
- Senior lawyer
- Lack of remorse
15.2 Keywords
- Contempt
- Court
- Justice
- Law
- Singapore
- Criminal
- Judgment
- Lawyer
- Bipolar
- Mental health
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Contempt of Court | 95 |
| Sentencing | 60 |
| Hypomanic episode of bipolar disorder | 50 |
| Legal Profession Act | 40 |
| Administrative Law | 30 |
| Civil Procedure | 20 |
| Duty of Candour | 15 |
| Evidence | 10 |
| Criminal Procedure | 10 |
16. Subjects
- Criminal Law
- Contempt of Court
- Sentencing
- Mental Health Law