"The Applicants therefore fail at the susceptibility requirement for the October Advisory. I dismiss the prayers for leave to seek quashing orders against the October Advisory." — Per Dedar Singh Gill J, Para 61
Case Information
- Citation: [2022] SGHC 141 (Para 0)
- Court: In the General Division of the High Court of the Republic of Singapore (Para 0)
- Date: 18 April 2022; judgment delivered on 16 June 2022 (Para 0)
- Coram: Dedar Singh Gill J (Para 0)
- Case Number: Originating Summons No 1313 of 2021 (Para 0)
- Area of Law: Administrative Law – Judicial review (Para 0)
- Counsel: Not answerable from the provided extract because no counsel names appear in the text excerpt.
- Judgment Length: Not answerable from the provided extract.
Summary
This was an administrative law challenge to two COVID-19-related measures: the Unvaccinated Medical Bills Policy and paragraph 7(c) of the October Advisory. The Applicants sought leave to commence judicial review proceedings, and also sought declarations that the measures were illegal, irrational, and in breach of Article 12(1) of the Constitution. The court framed the application as turning first on leave, then on the merits of the proposed declarations, and finally on the Applicants’ substantive legitimate expectation claims. (Para 2) (Para 45)
"This application is concerned with two aspects of the Government’s response to the COVID-19 pandemic, namely: (a) The decision announced on 8 November 2021 that COVID-19 patients who are unvaccinated by choice would be charged for their COVID-19 medical bills from 8 December 2021 … (b) The guidance in paragraph 7(c) of the ‘Updated Advisory on COVID-19 Vaccination at the Workplace’ dated 23 October 2021 …" — Per Dedar Singh Gill J, Para 2
The court held that the October Advisory was not susceptible to judicial review because it had no legal effect, and therefore leave to seek a quashing order against it had to be refused. By contrast, the Unvaccinated Medical Bills Policy was amenable to judicial review because it was an action taken pursuant to statutorily conferred powers and was public in nature. However, the Applicants still failed because they did not establish a prima facie case of reasonable suspicion that the policy was illegal, irrational, or unconstitutional. (Para 55) (Para 58) (Para 61) (Para 166)
"I accept that the Unvaccinated Medical Bills Policy is amenable to judicial review, being an action undertaken pursuant to statutorily conferred powers. It is also public in nature … Therefore, the Unvaccinated Medical Bills Policy satisfies the susceptibility requirement." — Per Dedar Singh Gill J, Para 55
The court also rejected the Applicants’ substantive legitimate expectation claims. It held that the Applicants had not shown any legitimate expectation that vaccination status would not affect either medical bill coverage or workplace consequences, because the Government had never made the representations alleged. The result was that leave, declaratory relief, and the substantive legitimate expectation claims all failed. (Para 17(c)) (Para 167) (Para 168)
"The Applicants’ further contention that the Government had breached their substantive legitimate expectations … fails. The doctrine does not apply in the present context because the Applicants are unable to prove the existence of any expectation which is legitimate and worthy of legal protection – the Government has never made the representations alleged by the Applicants." — Per Dedar Singh Gill J, Para 17(c)
What Were the Two Government Measures Challenged in This Judicial Review?
The application challenged two distinct measures arising from Singapore’s COVID-19 response. The first was the Unvaccinated Medical Bills Policy, announced on 8 November 2021, under which COVID-19 patients who were unvaccinated by choice would be charged for their COVID-19 medical bills from 8 December 2021. The second was paragraph 7(c) of the October Advisory, which addressed workplace arrangements for unvaccinated employees and stated that employers could terminate employment, as a last resort, with notice and in accordance with the employment contract, if unvaccinated employees were unable to perform their contracted work at the workplace and other options were unfeasible. (Para 2(a)) (Para 58)
"Paragraph 7(c) stated that employers can terminate their employment, as a last resort, with notice and in accordance with the employment contract, if unvaccinated employees are unable to perform their contracted work at the workplace and other options are unfeasible." — Per Dedar Singh Gill J, Para 58
The court’s summary of the factual setting made clear that the Government had initially announced full coverage of COVID-19 medical bills for all patients in public hospitals on 28 January 2020, before vaccines became available. The policy environment then changed as vaccination became available and remained voluntary, and the challenged measures were part of the Government’s evolving response to the pandemic. That context mattered because the court repeatedly distinguished between policy disagreement and legal unlawfulness. (Para 1) (Para 21)
"On 28 January 2020, the Government announced that it would fully cover the COVID-19 medical bills of all COVID-19 patients in public hospitals. Then came vaccines for the disease. The Government encourages vaccination. Vaccination, however, remains voluntary." — Per Dedar Singh Gill J, Para 1
The Applicants’ case was that these measures were unlawful, irrational, and constitutionally discriminatory, and that they also defeated expectations allegedly created by the Government’s earlier assurances and public messaging. The court treated those claims separately, first asking whether the measures could even be reviewed, then whether the Applicants had shown a prima facie basis for the relief sought, and finally whether any legitimate expectation had been established. (Para 45) (Para 46)
How Did the Court Frame the Leave Test for Judicial Review?
The court restated the familiar three-part leave threshold for judicial review. To obtain leave, the Applicants had to show that the subject matter was susceptible to judicial review, that they had sufficient interest in the matter, and that the materials before the court disclosed an arguable or prima facie case of reasonable suspicion in favour of the remedies sought. The court also explained that the leave stage serves as a filter against groundless claims and unnecessary burden on public bodies and the court. (Para 18) (Para 19)
"To obtain leave to commence judicial review proceedings, the Applicants must show that … (a) the subject matter of the complaint is susceptible to judicial review; (b) the applicants have sufficient interest in the matter; and (c) the materials before the court disclose an arguable or prima facie case of reasonable suspicion in favour of granting the remedies sought." — Per Dedar Singh Gill J, Para 18
The court emphasised that judicial review is not an appeal on the merits. Its role is to determine legality and constitutionality, not to decide whether a policy is wise, efficient, or preferable. That distinction was central to the court’s treatment of the Applicants’ statistical arguments, because the Applicants sought to use their own calculations to show that the Government’s policy rationale was wrong. The court repeatedly returned to the point that disagreement with policy is not the same as demonstrating legal error. (Para 21) (Para 74)
"The court’s role is in determining the legality and constitutionality of the law or executive decision/action, not in evaluating the merits of the particular legislation or policy decision (ie, to sustain the legality-merits distinction)." — Per Dedar Singh Gill J, Para 21
The court also noted that the three broad heads of judicial review in Singapore are illegality, irrationality, and procedural impropriety. Those grounds were the framework within which the Applicants’ challenge had to be assessed. The court further explained that unconstitutionality may, in an appropriate case, fall within illegality, and that the Article 12(1) challenge had to be analysed through the reasonable classification test. (Para 24) (Para 32) (Para 34)
"It is trite law that there are three broad heads of judicial review in Singapore, namely, illegality, irrationality and procedural impropriety." — Per Dedar Singh Gill J, Para 24
Why Was the October Advisory Held Not to Be Susceptible to Judicial Review?
The court held that the October Advisory failed at the susceptibility stage because it did not amount to a policy directive and did not carry legal effect. The court accepted that the advisory was guidance issued independently of any statutory power, and that it was not itself a legal instrument capable of being quashed. This meant that, even before reaching the merits, the Applicants could not obtain leave to seek a quashing order against it. (Para 58) (Para 61)
"The main difficulty that the Applicants face with the October Advisory is that it does not amount to a policy directive, nor does it carry legal effect." — Per Dedar Singh Gill J, Para 58
The court’s reasoning was anchored in the distinction between public guidance and legally operative decisions. It noted that the WVMs were implemented by subsidiary legislation and derived legal force from that legislation, whereas the October Advisory did not. The court therefore treated the advisory as lacking the kind of legal consequence that would make it a proper target for a quashing order. That distinction was decisive on susceptibility. (Para 58)
"The WVMs were instead implemented by subsidiary legislation (ie, Workplace Safety and Health (COVID-19 Safe Workplace) Regulations 2021), and derive their legal force from them." — Per Dedar Singh Gill J, Para 58
Because the advisory was not legally operative, the court dismissed the prayers for leave to seek quashing orders against it. The court’s conclusion was categorical: the Applicants failed at the threshold requirement, and the court did not need to proceed to a merits analysis of the advisory itself for purposes of quashing relief. (Para 61)
"The Applicants therefore fail at the susceptibility requirement for the October Advisory. I dismiss the prayers for leave to seek quashing orders against the October Advisory." — Per Dedar Singh Gill J, Para 61
Why Was the Unvaccinated Medical Bills Policy Held to Be Amenable to Judicial Review?
Unlike the October Advisory, the Unvaccinated Medical Bills Policy was held to be amenable to judicial review. The court accepted that it was an action undertaken pursuant to statutorily conferred powers and that it was public in nature. That satisfied the susceptibility requirement, so the Applicants were not stopped at the threshold in relation to that policy. (Para 55)
"I accept that the Unvaccinated Medical Bills Policy is amenable to judicial review, being an action undertaken pursuant to statutorily conferred powers. It is also public in nature … Therefore, the Unvaccinated Medical Bills Policy satisfies the susceptibility requirement." — Per Dedar Singh Gill J, Para 55
The court’s analysis drew a line between a reviewable public decision and a non-reviewable advisory. It observed that the policy was not merely informational; it was a governmental decision with practical and legal consequences, and it was tied to the exercise of public power. That was enough to bring it within the scope of judicial review, even though the Applicants still had to show a prima facie case on the substantive grounds. (Para 55)
However, susceptibility did not mean success. The court proceeded to examine whether the Applicants had shown an arguable case of illegality, irrationality, or breach of Article 12(1), and whether their legitimate expectation claims could stand. On each of those matters, the court concluded that the Applicants had not met the required threshold. (Para 166) (Para 167) (Para 168)
How Did the Court Deal with the Applicants’ Statistical Challenge to the Policy Rationale?
The Applicants attempted to undermine the Government’s efficacy rationale by constructing their own statistics from publicly available COVID-19 data. They argued that the Government’s contention—that fully vaccinated persons had less chance of dying from COVID-19 or falling seriously ill—was not borne out by the statistics. The court considered the Applicants’ Death Statistics, CI Statistics, and 10 April 2022 Statistics, but it did not accept that those figures established the proposition the Applicants sought to prove. (Para 15(a)) (Para 78)
"The Applicants submit as follows: (a) The MTF’s contention that a person who is fully vaccinated would have less chance of dying from the COVID-19 virus or falling seriously ill is not borne out by the statistics." — Per Dedar Singh Gill J, Para 15(a)
The court explained that the Applicants’ statistics were not a reliable basis for the legal conclusions they wanted to draw. It noted that the Applicants computed statistics from publicly available data, but the court was not persuaded that those computations displaced the Government’s policy basis. The court’s response was not to engage in a competing scientific adjudication, but to say that the statistics did not assist the Applicants in their protest against the efficacy rationale. (Para 78) (Para 74)
"The Applicants compute statistics from COVID-19 data made publicly available by MOH to arrive at the Death and CI Statistics …" — Per Dedar Singh Gill J, Para 78
The court’s conclusion was explicit: the statistics did not help the Applicants. The court stressed that it was not its role to make pronouncements on the laws of nature, but to adjudicate man-made laws and executive decisions. That observation was particularly important in a case where the Applicants sought to turn epidemiological disagreement into a judicial review challenge. (Para 73) (Para 74)
"It is not the court’s role to make pronouncements on the laws of nature, but to set down and adjudicate man-made laws to govern society." — Per Dedar Singh Gill J, Para 73
Did the Court Accept the Applicants’ Argument that the Policy Was Irrational or Illegal?
No. The court held that the Applicants had not shown that the Unvaccinated Medical Bills Policy was irrational, illegal, or in breach of Article 12(1). The court’s reasoning was that the Applicants’ statistical material did not establish that the Government’s policy choice lacked a rational basis, and that the policy fell within the lawful exercise of executive power. The court therefore refused leave to pursue quashing relief on those grounds. (Para 166) (Para 167)
"The Applicants have not shown that the Unvaccinated Medical Bills Policy is irrational, illegal or in breach of Art 12(1)." — Per Dedar Singh Gill J, Para 166
The court’s treatment of irrationality was consistent with the orthodox Wednesbury approach. It referred to the established principle that irrationality concerns a decision so unreasonable that no reasonable authority could ever have come to it. The court also reiterated that judicial review is concerned with the manner of exercise of power, not with substituting the court’s own view of the merits. In that light, the Applicants’ disagreement with the policy’s wisdom could not establish irrationality. (Para 24) (Para 21)
"The court’s role is in determining the legality and constitutionality of the law or executive decision/action, not in evaluating the merits of the particular legislation or policy decision (ie, to sustain the legality-merits distinction)." — Per Dedar Singh Gill J, Para 21
The court also rejected the Applicants’ attempt to characterise the policy as illegal. It treated the policy as a lawful executive response within the Government’s powers, and it did not accept that the Applicants had shown any relevant legal defect in the decision-making process or in the scope of the power exercised. Accordingly, the leave application failed on the prima facie reasonable suspicion limb as well. (Para 166) (Para 167)
How Did Article 12(1) and the Reasonable Classification Test Apply?
The court set out the Article 12(1) framework by stating that all persons are equal before the law and entitled to equal protection of the law. It then explained that a challenge under Article 12(1) turns on whether the executive action treated the applicant differently from other equally situated persons, and whether that differential treatment was reasonable because it was based on legitimate reasons. That is the reasonable classification test. (Para 32) (Para 34)
"Article 12(1) of the Constitution (‘Art 12(1)’) provides that ‘[a]ll persons are equal before the law and entitled to the equal protection of the law’." — Per Dedar Singh Gill J, Para 32
"Whether an administrative act or decision has breached Art 12(1) would turn on the following … (a) whether the executive action or administrative decision resulted in the applicant being treated differently from other equally situated persons; and (b) whether this differential treatment was reasonable in that it was based on legitimate reasons (the ‘reasonable classification test’)." — Per Dedar Singh Gill J, Para 34
The Applicants argued that the policy discriminated against the unvaccinated. The court, however, did not accept that the Article 12(1) challenge was made out. It approached the issue through the lens of constitutional classification and the presumption of constitutionality, and it concluded that the Applicants had not shown that the policy treated equally situated persons differently in a constitutionally impermissible way. (Para 34) (Para 166)
The court’s analysis also reflected the broader principle that public acts are presumed constitutional unless shown otherwise. In this case, the Applicants’ evidence did not displace that presumption. The court therefore refused to treat the policy as constitutionally suspect merely because it differentiated between vaccinated and unvaccinated persons in the context of pandemic-related healthcare financing. (Para 166)
What Did the Court Say About the Government’s Policy Rationale and the Evidence of Dr Heng?
The court considered the Government’s explanation for the policy, including the affidavit evidence of Dr Heng. The extract records that Dr Heng stated there would be clear differences between each sub-group in the non-fully vaccinated population. That evidence was relevant to the Government’s position that the Applicants’ statistical comparisons were too crude to support the conclusions they sought to draw. (Para 87)
"Dr Heng further states that there would be clear differences between each sub-group in the non-fully vaccinated population." — Per Dedar Singh Gill J, Para 87
The court accepted that the Government’s policy was based on a broader and more nuanced assessment than the Applicants’ calculations suggested. It did not treat the Applicants’ statistics as a complete or reliable substitute for the Government’s policy analysis. Instead, it held that the statistics did not assist the Applicants in their protest against the efficacy rationale. (Para 74) (Para 87)
That approach is consistent with the court’s repeated insistence that judicial review is not a forum for re-litigating policy judgments through selective data analysis. The court did not say that statistics are irrelevant in principle; rather, it said that the particular statistics advanced by the Applicants did not establish the legal propositions necessary for relief. (Para 21) (Para 74)
Why Did the Substantive Legitimate Expectation Claims Fail?
The Applicants also relied on substantive legitimate expectation. The court rejected those claims because the Applicants could not prove the existence of any expectation that was legitimate and worthy of legal protection. In particular, the court held that the Government had never made the representations alleged by the Applicants. Without a clear representation, there could be no protected expectation of the kind the doctrine requires. (Para 17(c))
"The Applicants’ further contention that the Government had breached their substantive legitimate expectations … fails. The doctrine does not apply in the present context because the Applicants are unable to prove the existence of any expectation which is legitimate and worthy of legal protection – the Government has never made the representations alleged by the Applicants." — Per Dedar Singh Gill J, Para 17(c)
The court’s treatment of substantive legitimate expectation was consistent with the limited role that doctrine plays in Singapore public law. The court referred to authority indicating that the doctrine is not generally available to override lawful policy changes absent a clear and specific representation. Here, the Applicants’ case failed at the threshold because the factual foundation for the alleged expectation was missing. (Para 17(c)) (Para 45)
As a result, the legitimate expectation claims did not provide an independent route to relief. The court dismissed them together with the other prayers, because the Applicants had not shown a legal basis for the court to compel the Government to maintain the earlier position on medical bill coverage or workplace consequences. (Para 167) (Para 168)
How Did the Court Treat the Relationship Between the WVMs and the October Advisory?
The court distinguished carefully between the legal force of the WVMs and the advisory character of the October Advisory. The WVMs were implemented by subsidiary legislation and derived legal force from that legislation. The October Advisory, by contrast, was guidance and not itself a policy directive with legal effect. That distinction explained why one measure was reviewable and the other was not. (Para 58)
"The WVMs were instead implemented by subsidiary legislation (ie, Workplace Safety and Health (COVID-19 Safe Workplace) Regulations 2021), and derive their legal force from them." — Per Dedar Singh Gill J, Para 58
This distinction mattered not only for susceptibility, but also for the structure of the Applicants’ challenge. The Applicants sought to attack both measures together, but the court treated them separately because their legal character was different. The policy on medical bills was a public act with legal consequences; the workplace advisory was not. The court’s analysis therefore demonstrates that judicial review depends on the nature of the impugned act, not merely on its subject matter or political significance. (Para 55) (Para 58)
That approach also reflects the court’s broader concern to preserve the legality-merits distinction. A document may be important in public debate without being legally operative. The court’s refusal to quash the October Advisory shows that not every governmental communication is a proper target for prerogative relief. (Para 21) (Para 61)
Why Does This Case Matter?
This case matters because it applies core Singapore judicial review principles to a high-profile public health dispute. It confirms that the court will scrutinise whether a measure is legally reviewable before reaching the merits, and that a government advisory without legal effect will not be quashed simply because it influences conduct in practice. That is a significant clarification for public law challenges to executive guidance. (Para 55) (Para 58) (Para 61)
"The court’s role is in determining the legality and constitutionality of the law or executive decision/action, not in evaluating the merits of the particular legislation or policy decision (ie, to sustain the legality-merits distinction)." — Per Dedar Singh Gill J, Para 21
The case is also important for its treatment of Article 12(1) and substantive legitimate expectation. It shows that constitutional equality arguments must be grounded in a proper comparison between equally situated persons and a demonstrable lack of legitimate justification. It also shows that substantive legitimate expectation will fail where the alleged representation cannot be established. For practitioners, the case is a reminder that public law challenges to pandemic measures must be built on legally cognisable acts, clear representations, and evidence capable of meeting the leave threshold. (Para 34) (Para 17(c)) (Para 166)
Finally, the judgment is notable for its insistence that courts are not the forum for resolving scientific or epidemiological disputes as such. The court’s statement that it is not its role to pronounce on the laws of nature underscores the limits of judicial review in technically complex policy areas. That has broader implications beyond COVID-19, especially where litigants seek to convert contested data into a legal challenge to executive policy. (Para 73) (Para 74)
Cases Referred To
| Case Name | Citation | How Used | Key Proposition |
|---|---|---|---|
| Syed Suhail bin Syed Zin v Attorney-General | [2021] 1 SLR 809 | Used for the leave test and Article 12(1) framework | Leave requires susceptibility, sufficient interest, and prima facie reasonable suspicion |
| Gobi a/l Avedian and another v Attorney-General and another appeal | [2020] 2 SLR 883 | Used for leave threshold and standing/declaratory relief | Leave filters out groundless cases; declarations require a real interest and real controversy |
| Lee Pheng Lip Ian v Chen Fun Gee and others | [2020] 1 SLR 586 | Used on the purpose of the leave threshold | Leave prevents waste of judicial time and harassment of public bodies |
| Chng Suan Tze v Minister for Home Affairs and others and other appeals | [1988] 2 SLR(R) 525 | Used for rule of law and irrationality definition | All power has legal limits; irrationality is assessed by the Wednesbury standard |
| SGB Starkstrom Pte Ltd v Commissioner for Labour | [2016] 3 SLR 598 | Used on judicial review scope and substantive legitimate expectation doctrine | Separation of powers limits judicial intervention; substantive legitimate expectation is not generally accepted |
| Wong Keng Leong Rayney v Law Society of Singapore | [2006] 4 SLR(R) 934 | Used on judicial review scope | Court intervention in administrative action is qualified |
| Tan Seng Kee v Attorney-General and other appeals | [2022] SGCA 16 | Used on separation of powers, substantive legitimate expectation, scientific questions, and Article 12(1) | Courts do not pronounce on scientific laws of nature; limited recognition of substantive legitimate expectation |
| Associated Provincial Picture Houses, Limited v Wednesbury Corporation | [1948] 1 KB 223 | Used for irrationality standard | Wednesbury unreasonableness |
| Lines International Holding (S) Pte Ltd v Singapore Tourist Promotion Board and another | [1997] 1 SLR(R) 52 | Used on judicial review versus appeal distinction | Judicial review concerns process, not merits |
| Re Dow Jones Publishing (Asia) Inc’s Application | [1988] 1 SLR(R) 418 | Used on process versus merits distinction | Judicial review concerns the manner of exercise of power |
| Tan Seet Eng v Attorney-General and another matter | [2016] 1 SLR 779 | Used for illegality and irrationality definitions | Illegality concerns scope and purpose; irrationality is substantive |
| Chee Siok Chin and others v Minister for Home Affairs and another | [2006] 1 SLR(R) 582 | Used for procedural impropriety | Natural justice principles apply to procedural impropriety |
| Inland Revenue Commissions v National Federation of Self Employed and Small Businesses Ltd | [1982] 1 AC 617 | Used on court versus Parliament roles | Parliament judges policy and efficiency; courts judge lawfulness |
| Council of Civil Service Unions and others v Minister for the Civil Service | [1985] AC 374 | Used for illegality definition | Relevant and irrelevant considerations are central to legality review |
| De Smith’s Judicial Review | Secondary authority | Used as doctrinal support on illegality and legitimate expectations | Explains the structure of judicial review and legitimate expectation doctrine |
| Halsbury’s Laws of Singapore - Administrative and Constitutional Law | Secondary authority | Used for procedural impropriety | Summarises natural justice and procedural review |
| Tan Hon Leong Eddie v Attorney-General | [2022] 3 SLR 639 | Used on unconstitutionality and illegality | Unconstitutionality may fall within illegality |
| Attorney General v Datchinamurthy a/l Kataiah | [2022] SGCA 46 | Used on unconstitutionality and leave | Unconstitutionality can satisfy prima facie reasonable suspicion |
| Vellama d/o Marie Muthu v Attorney-General | [2012] 4 SLR 698 | Used on declarations and leave | No leave is needed for declaration alone, but declaratory relief under O 53 depends on leave for prerogative orders |
| Manjit Singh s/o Kirpal Singh and another v Attorney-General | [2013] 2 SLR 1108 | Used on susceptibility and declarations | Statutory or public power may be amenable to review |
| Regina (Beer (trading as Hammer Trout Farm)) v Hampshire Farmers’ Markets Ltd | [2004] 1 WLR 233 | Used on the public element test | Public law functions may be reviewable |
| Comptroller of Income Tax v ACC | [2010] 2 SLR 1189 | Used on quashing orders and legal effect | Only decisions with legal effect can be quashed |
| Ong Ah Chuan and another v Public Prosecutor | [1979]–[1980] SLR(R) 710 | Used on equal protection | Equal protection requires like to be compared with like |
| Ramalingam Ravinthran v Attorney-General | [2012] 2 SLR 49 | Used on presumption of constitutionality | Public acts are presumed constitutional |
| Saravanan Chandaram v Public Prosecutor and another matter | [2020] 2 SLR 95 | Used on presumption of constitutionality | Executive acts are not presumptively suspect |
| Wham Kwok Han Jolovan v Public Prosecutor | [2021] 1 SLR 476 | Used on presumption of constitutionality | Same proposition on constitutional presumption |
| Nagaenthran a/l K Dharmalingam v Public Prosecutor and another appeal | [2019] 2 SLR 216 | Used on scientific questions not suited to courts | Courts have limited tools for scientific issues |
| Tan Eng Hong v Attorney-General | [2012] 4 SLR 476 | Used on declaratory relief standing | Declaratory relief requires a real interest and real controversy |
Legislation Referenced
- Constitution of the Republic of Singapore — Article 12(1), Article 23, Article 30, First Schedule, Ninth Schedule (Para 32) (Para 54)
- Constitution of the Republic of Singapore (1985 Rev Ed, 1999 Reprint) (Para 54)
- Constitution of the Republic of Singapore (Ministerial Responsibility) Notification 2020 (Para 54)
- Workplace Safety and Health (COVID-19 Safe Workplace) Regulations 2021 (Para 58)
- Rules of Court, Order 53 r 1 (Para 18) [CDN] [SSO]
Source Documents
This article analyses [2022] SGHC 141 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the full judgment for the Court's complete reasoning.