Ang Yong Guan v Singapore Medical Council: Professional Misconduct & Medical Malpractice

In 2025, the Court of 3 Judges of the General Division of the High Court heard appeals by both Dr. Ang Yong Guan and the Singapore Medical Council (SMC) regarding a Disciplinary Tribunal's decision concerning Dr. Ang's treatment of a patient. The court found Dr. Ang liable for three charges of professional misconduct under the Medical Registration Act for inappropriate prescriptions, setting aside the original conviction on professional services charges. The court imposed a 36-month suspension on Dr. Ang.

1. Case Overview

1.1 Court

Court of 3 Judges of the General Division of the High Court

1.2 Outcome

Appeal dismissed; Dr. Ang Yong Guan suspended for 36 months.

1.3 Case Type

Regulatory

1.4 Judgment Type

Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Dr. Ang Yong Guan was found liable for professional misconduct for inappropriate prescriptions, leading to a 36-month suspension. The case highlights medical professional standards.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Dr Ang Yong GuanAppellant, RespondentIndividualAppeal dismissedLost
Singapore Medical CouncilRespondent, AppellantStatutory BoardAppeal allowed in partPartial

3. Judges

Judge NameTitleDelivered Judgment
Sundaresh MenonChief JusticeNo
Tay Yong KwangJustice of the Court of AppealNo
Belinda Ang Saw EanJustice of the Court of AppealYes

4. Counsels

Counsel NameOrganization
Christopher Chong Fook ChoyDentons Rodyk & Davidson LLP
Sim Mei Jun AudreyDentons Rodyk & Davidson LLP
Chandra Mohan K NairTan Rajah & Cheah LLP
Kronenburg Edmund JeromeBraddell Brothers LLP
Thng Yu TingBraddell Brothers LLP
Angelia ChanBraddell Brothers LLP
Colin Wu GuolinBraddell Brothers LLP
Chan Yu JieBraddell Brothers LLP

4. Facts

  1. Dr. Ang prescribed multiple benzodiazepines concurrently to the Patient.
  2. Dr. Ang prescribed benzodiazepines concurrently with opioid analgesics to the Patient.
  3. Dr. Ang prescribed 60mg of Mirtazapine, exceeding the permitted maximum daily dosage of 45mg.
  4. Dr. Ang prescribed 25mg of Zolpidem CR, exceeding the permitted maximum daily dosage of 12.5mg.
  5. The Patient's cause of death was certified as multi-organ failure due to mixed drug intoxication.
  6. Dr. Ang conceded that his prescription of 60mg of Mirtazapine per night went to the edge of the killing range.

5. Formal Citations

  1. Dr Ang Yong Guan v Singapore Medical Council, Originating Applications Nos 8 of 2023 and 9 of 2023, [2025] SGHC 17
  2. Singapore Medical Council v Dr Ang Yong Guan, , [2023] SMCDT 2
  3. Ang Yong Guan v Singapore Medical Council and another matter, , [2024] 4 SLR 1364

6. Timeline

DateEvent
Dr. Ang began treating Mr. Quek Kiat Siong.
Dr. Ang issued the last prescription to Mr. Quek Kiat Siong.
Mr. Quek Kiat Siong passed away.
Court of Appeal found that the quantity and variety of drugs prescribed to the patient could have resulted in his death.
Patient’s sister filed a complaint against Dr. Ang with the SMC.
Originating Applications Nos 8 and 9 of 2023 were filed.
Parties were heard on the appropriate sentence.
Judgment reserved.

7. Legal Issues

  1. Professional Misconduct
    • Outcome: The court found Dr. Ang liable for professional misconduct.
    • Category: Substantive
    • Sub-Issues:
      • Inappropriate prescription of medication
      • Departure from medical standards
      • Failure to obtain informed consent
    • Related Cases:
      • [2024] 4 SLR 1364
  2. Sentencing
    • Outcome: The court imposed a 36-month suspension.
    • Category: Procedural
    • Sub-Issues:
      • Levels of harm and culpability
      • Aggravating and mitigating factors
      • Concurrent vs. consecutive sentences
      • Inordinate delay in prosecution
    • Related Cases:
      • [2019] 3 SLR 526

8. Remedies Sought

  1. Suspension from practice
  2. Censure
  3. Written undertaking

9. Cause of Actions

  • Professional Misconduct

10. Practice Areas

  • Medical Malpractice
  • Disciplinary Proceedings

11. Industries

  • Healthcare

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Singapore Medical Council v Dr Ang Yong GuanDisciplinary TribunalYes[2023] SMCDT 2SingaporeOriginal Disciplinary Tribunal decision that was appealed.
Ang Yong Guan v Singapore Medical Council and another matterCourt of 3 Judges of the General Division of the High CourtYes[2024] 4 SLR 1364SingaporeLiability Judgment, where the court found Dr. Ang liable for professional misconduct.
Quek Kwee Kee Victoria (executor of the estate of Quek Kiat Siong, deceased) and another v American International Assurance Co Ltd and anotherCourt of AppealYes[2017] 1 SLR 461SingaporeCivil proceedings where the Court of Appeal found the quantity and variety of drugs prescribed to the patient could have resulted in his death.
Wong Meng Hang v Singapore Medical Council and other mattersCourt of 3 Judges of the General Division of the High CourtYes[2019] 3 SLR 526SingaporeEstablished the sentencing framework for offences under the Medical Registration Act.
Singapore Medical Council v Ling Chia TienHigh CourtYes[2024] SGHC 283SingaporeDiscussed the application of the one-transaction rule and the totality principle in disciplinary proceedings.
Singapore Medical Council v Dr Tan Kok JinDisciplinary TribunalYes[2019] SMCDT 3SingaporeCited as a precedent for benzodiazepine-related cases involving potential harm.
Singapore Medical Council v Dr Eugene UngDisciplinary TribunalYes[2021] SMCDT 4SingaporeCited as a precedent for benzodiazepine-related cases involving potential harm.
Singapore Medical Council v Dr Ling Chia TienDisciplinary TribunalYes[2023] SMCDT 7SingaporeCited as a precedent for benzodiazepine-related cases involving potential harm.
Singapore Medical Council v Wee Teong BooCourt of 3 Judges of the General Division of the High CourtYes[2023] 4 SLR 1328SingaporeCited for drawing inferences from facts and culpability assessment.
Singapore Medical Council v Dr Tham Ngiap BooDisciplinary TribunalYes[2023] SMCDT 4SingaporeCited for comparison regarding profit motive and culpability.
Ang Peng Tiam v Singapore Medical Council and another matterCourt of 3 Judges of the General Division of the High CourtYes[2017] 5 SLR 356SingaporeCited for the principle that an offender’s eminence and seniority is an aggravating factor.
Singapore Medical Council v Dr Chia Kiat SwanDisciplinary TribunalYes[2019] SMCDT 1SingaporeCited for the proposition that there is a benchmark period of 3 years that attracted a discount of 50% on the period of suspension in some past cases.
Jen Shek Wei v Singapore Medical CouncilCourt of 3 Judges of the General Division of the High CourtYes[2018] 3 SLR 943SingaporeCited for inordinate delay in prosecution.
Wong Poon Kay v Public ProsecutorCourt of AppealYes[2024] 4 SLR 453SingaporeCited for the principles regarding sentencing discounts due to inordinate delay.
Law Society of Singapore v Yap Bock Heng ChristopherCourt of AppealYes[2014] 4 SLR 877SingaporeCited for the power to impose consecutive periods of suspension.
Wee Teong Boo v Singapore Medical Council (Attorney-General intervener)Court of AppealYes[2023] 3 SLR 705SingaporeCited for disciplinary proceedings being quasi-criminal in nature.
Low Chai Ling v Singapore Medical CouncilCourt of AppealYes[2013] 1 SLR 83SingaporeCited for disciplinary proceedings being quasi-criminal in nature.
Haliffie bin Mamat v Public Prosecutor and other appealsCourt of AppealYes[2016] 5 SLR 636SingaporeCited for the totality principle.
Gan Chai Bee Anne v Public ProsecutorCourt of AppealYes[2019] 4 SLR 838SingaporeCited for the totality principle.
Seah Ming Yang Daryle v Public ProsecutorCourt of AppealYes[2024] 4 SLR 1561SingaporeCited for the totality principle.
Public Prosecutor v Su Jiqing JoelCourt of AppealYes[2021] 3 SLR 1232SingaporeCited for the totality principle.
Public Prosecutor v Jeffrey PeHigh CourtYes[2023] SGHC 313SingaporeCited for the principle that Dr. Ang was entitled to defend himself before the DT and avail himself of his right of appeal.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Medical Registration Act (Cap 174, 2014 Rev Ed) s 53(1)(d)Singapore
Medical Registration Act (Cap 174, 2014 Rev Ed) s 53(1)(e)Singapore
Medical Registration Act (Cap 174, 2014 Rev Ed) s 53(2)(b)Singapore
Medical Registration Act (Cap 174, 2014 Rev Ed) s 53(2)(h)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Professional misconduct
  • Medical Registration Act
  • Benzodiazepines
  • Opioid analgesics
  • Mirtazapine
  • Zolpidem CR
  • Sentencing guidelines
  • Harm
  • Culpability
  • Inordinate delay
  • One-transaction rule
  • Totality principle

15.2 Keywords

  • Medical misconduct
  • Drug prescription
  • Singapore Medical Council
  • Disciplinary Tribunal
  • Medical negligence

17. Areas of Law

Area NameRelevance Score
Medical Malpractice90
Professional Liability80
Healthcare Law70
Pharmaceutical Law60
Medical Ethics50
Litigation30
Criminal Law20

16. Subjects

  • Medical Profession
  • Medical Ethics
  • Pharmaceutical Law
  • Administrative Law