PUBLIC PROSECUTOR v Eddie Lee Zheng Da & Yap Peng Keong, Darren

"In short, I do not find Lee’s evidence that he only intended to traffic in three ‘halves’ of heroin to be credible. In my judgment, on the evidence before me, Lee has failed to rebut the presumption in s 17(c) of the MDA that he was in possession of the Three Bundles, which contained not less than 24.21g of diamorphine, for the purpose of trafficking. Accordingly, I find that the elements of the trafficking charge under s 5(1)(a) read with s 5(2) of the MDA against Lee have been proven beyond reasonable doubt, and I convict him accordingly." — Per Ang Cheng Hock J, Para 82

Case Information

• Citation: [2022] SGHC 199 (Para 0)
• Court: General Division of the High Court of the Republic of Singapore (Para 0)
• Date of Judgment: 24 August 2022 (Para 0)
• Coram: Ang Cheng Hock J (Para 0)
• Case Number: Criminal Case No 52 of 2021 (Para 0)
• Area of Law: Criminal Law — Statutory offences — Misuse of Drugs Act (Para 0)
• Counsel for the Prosecution: Not answerable from the extraction provided (NOT ANSWERABLE)
• Counsel for the Accused Persons: Not answerable from the extraction provided (NOT ANSWERABLE)
• Judgment Length: Not answerable from the extraction provided (NOT ANSWERABLE)

Summary

This was a joint trial arising from a drug transaction on 4 July 2018 involving Lee and Yap, in which three bundles of heroin were delivered to Lee at the Pan Pacific Singapore hotel room he had checked into earlier that day. The Prosecution’s case was that Lee had ordered heroin from his supplier and that Yap collected and delivered the drugs to him; Lee’s defence was that he had ordered only three half-pound packets but was mistakenly supplied with three one-pound packets instead. Yap’s evidence was that he collected drugs at Lee’s instructions, but he denied knowing the nature or quantity of the drugs when he did so. (Paras 4, 8, 10, 12, 19, 21, 25)

The court’s central task in relation to Lee was whether he had rebutted the presumption of trafficking under s 17(c) of the Misuse of Drugs Act. The judge held that Lee’s account was not credible, emphasising that the alleged oversupply defence was raised late, shifted over time, and was not supported by objective evidence such as the phone records or Yap’s testimony. The court therefore concluded that Lee had failed to rebut the presumption and convicted him of trafficking under s 5(1)(a) read with s 5(2) of the MDA. (Paras 37, 50, 51, 58, 59, 72, 82)

The judgment also set out the statutory framework and the authorities governing trafficking, possession, knowledge, and the evidential consequences of lies and omissions in cautioned statements. The court relied on established Singapore authorities to explain that the Prosecution must prove possession, knowledge of the nature of the drug, and possession for the purpose of trafficking, while the accused bears the legal burden of rebutting the trafficking presumption on a balance of probabilities. (Paras 31, 32, 33, 35, 37, 50, 82)

What Were the Charges Against Lee and Yap?

The indictment charged Lee with trafficking in a Class A controlled drug by having in his possession for the purpose of trafficking three packets containing not less than 1352.8g of granular/powdery substance, which was analysed and found to contain not less than 24.21g of diamorphine. The charge alleged that this occurred on 4 July 2018 at about 10.10pm in room 2613 of Pan Pacific Singapore, and that the offence was committed without authorisation under the MDA or its regulations. (Para 1)

Yap was charged in parallel with trafficking in the same controlled drug by delivering the three packets to Lee at the same time and place. The charge framed his conduct as delivery of the three packets containing not less than 1352.8g of granular/powdery substance, which was analysed and found to contain not less than 24.21g of diamorphine, to Lee. The court’s analysis later treated Yap’s role as the collection-and-delivery link in the chain of events leading to Lee’s possession. (Para 2, 38)

"you, 1. EDDIE LEE ZHENG DA, on 4 July 2018, at about 10.10pm, at room number 2613 of Pan Pacific Singapore, located at 7 Raffles Boulevard, Singapore, did traffic in a Class ‘A’ controlled drug listed in the First Schedule to the Misuse of Drugs Act (Cap 185, 2008 Rev Ed), to wit, by having in your possession for the purpose of trafficking, three packets containing a total of not less than 1352.8g of granular/powdery substance, which was analysed and found to contain a total of not less than 24.21g of diamorphine, without authorisation under the said Act or the regulations made thereunder, and you have thereby committed an offence under section 5(l)(a) read with section 5(2) and punishable under section 33(1) of the said Act" — Per Ang Cheng Hock J, Para 1

"you, 2. YAP PENG KEONG, DARREN, are charged that you, on 4 July 2018, at about 10.10pm, at room number 2613 of Pan Pacific Singapore, located at 7 Raffles Boulevard, Singapore, did traffic in a Class ‘A’ controlled drug listed in the First Schedule to the Misuse of Drugs Act (Cap 185, 2008 Rev Ed), to wit, by delivering three packets containing a total of not less than 1352.8g of granular/powdery substance, which was analysed and found to contain a total of not less than 24.21g of diamorphine, to one Eddie Lee Zheng Da" — Per Ang Cheng Hock J, Para 2

How Did the Drug Transaction Unfold on 4 July 2018?

The factual narrative began with Lee checking into the Pan Pacific Singapore in the afternoon of 4 July 2018 and being assigned room 2613. He was accompanied by his girlfriend, Passara. The court treated this as the starting point for the events that culminated in the delivery of the drugs to the room later that night. (Para 4)

According to the agreed facts and the evidence, Lee instructed Yap to collect drugs from 28/30 Gul Avenue and deliver them to the hotel room. Yap drove there, waited for about 30 minutes, and then met an unidentified male motorcyclist who arrived on a bike. Yap handed over cash to the motorcyclist, and in exchange the motorcyclist threw three bundles of heroin and two blocks of cannabis onto the front passenger seat of Yap’s car. The court accepted this as the mechanism by which the drugs moved from the supplier’s side into Yap’s custody. (Para 8)

Yap then drove back to the hotel and brought the drugs into the room. In the room, he took out the three bundles and the remaining block of cannabis, and Lee weighed the three bundles and the block of cannabis using a weighing scale on the table. The court later relied on this sequence as part of the objective context against which Lee’s oversupply defence had to be assessed. (Para 10)

Shortly thereafter, CNB officers forcibly entered the room and arrested Lee, Yap, and Passara. That arrest marked the end of the transaction and the beginning of the evidential contest at trial, including the significance of the statements recorded from Lee and the objective phone evidence later analysed by the court. (Para 12)

"In the afternoon of 4 July 2018, Lee checked into the Pan Pacific Singapore, a hotel which is located along Raffles Boulevard (‘the Hotel’). He was given room 2613 (‘the Room’). Lee was accompanied by his girlfriend, one Nomsutham Passara (‘Passara’)." — Per Ang Cheng Hock J, Para 4

"Yap drove his car to 28/30 Gul Avenue. There, he waited in his car for about 30 minutes, while it was parked at the side of the road. Then, an unidentified male motorcyclist arrived and stopped his bike next to Yap’s car. Yap passed the motorcyclist the Cash. In exchange, the motorcyclist threw three bundles of heroin … and two blocks of cannabis … onto the front passenger seat of Yap’s car." — Per Ang Cheng Hock J, Para 8

"In the Room, Yap took out the Three Bundles and the remaining block of cannabis … Lee then weighed the Three Bundles (as well as the block of cannabis) using a weighing scale on the table." — Per Ang Cheng Hock J, Para 10

"At around this time, officers from the Central Narcotics Bureau (‘CNB’) forcibly entered the Room, and arrested Lee, Yap and Passara." — Per Ang Cheng Hock J, Para 12

What Statutory Framework Did the Court Apply to the Trafficking Charge?

The court set out the core trafficking provision in s 5 of the MDA. Section 5(1)(a) makes it an offence, unless authorised, for a person to traffic in a controlled drug, and s 5(2) provides that a person commits trafficking if he has the drug in his possession for the purpose of trafficking. The judgment also reproduced the statutory definition of “traffic” and “trafficking,” which includes acts such as selling, giving, administering, transporting, sending, delivering, or distributing, or offering to do those acts. (Paras 31, 32)

The court also referred to the presumption in s 17(c) of the MDA, which presumes that a person proved to have had in his possession more than 2 grammes of diamorphine had that drug in possession for the purpose of trafficking unless the contrary is proved. That presumption was central to Lee’s case because the Prosecution’s position was that once possession and knowledge were shown, the burden shifted to Lee to rebut the trafficking purpose. (Paras 19, 37)

In addition, the court referred to the presumptions in s 18(1)(a) and s 18(2) of the MDA, and to the CPC provisions governing cautioned statements and adverse inferences. The judge used those provisions to explain why Lee’s failure to mention his oversupply defence at the earliest opportunity mattered, and why the court could draw an adverse inference from the omission. (Paras 18, 50)

"5.—(1) Except as authorised by this Act, it shall be an offence for a person, on his own behalf or on behalf of any other person, whether or not that other person is in Singapore — (a) to traffic in a controlled drug; … (2) For the purposes of this Act, a person commits the offence of trafficking in a controlled drug if he has in his possession that drug for the purpose of trafficking." — Per Ang Cheng Hock J, Para 31

"(a) to sell, give, administer, transport, send, deliver or distribute; or (b) to offer to do anything mentioned in paragraph (a), otherwise than under the authority of this Act, and ‘trafficking’ has a corresponding meaning" — Per Ang Cheng Hock J, Para 32

"Any person who is proved to have had in his possession more than — (c) 2 grammes of diamorphine; … shall be presumed to have had that drug in possession for the purpose of trafficking unless it is proved that his possession of that drug was not for that purpose" — Per Ang Cheng Hock J, Para 19

How Did the Court Frame the Issues for Decision?

The judge said that, after reviewing the evidence and the parties’ written and oral submissions, the issues were “quite narrowly defined.” For Lee, the only real issue was whether he had rebutted the presumption that he intended to traffic in not less than 24.21g of diamorphine. The court therefore did not treat the case as one turning on whether Lee had possession in the ordinary sense; rather, the dispute was whether his explanation displaced the statutory trafficking presumption. (Paras 34, 37)

For Yap, the court noted that it was undisputed that he had agreed to collect drugs from 28/30 Gul Avenue at Lee’s instructions and deliver them to Lee at the hotel room, and that the three bundles were part of those drugs. The court’s later discussion of Yap’s evidence focused on whether his account could assist Lee’s oversupply defence or whether it instead undermined it. (Para 38)

"From my review of the evidence and the closing submissions, both written and oral, the issues that I have to decide are quite narrowly defined." — Per Ang Cheng Hock J, Para 34

"The only issue before the court in relation to the charge against Lee, therefore, is whether he has rebutted the presumption that he intended to traffic in not less than 24.21g of diamorphine." — Per Ang Cheng Hock J, Para 37

"As for Yap, it is undisputed, and it is also his evidence at the trial that he had agreed to collect drugs from 28/30 Gul Avenue at Lee’s instructions and deliver them to Lee at the Room in the Hotel, and that the Three Bundles were part of these drugs …" — Per Ang Cheng Hock J, Para 38

What Did the Prosecution and the Defence Argue About Lee’s Alleged Oversupply?

The Prosecution’s case was straightforward: Lee had ordered heroin from his supplier, and the three bundles collected by Yap and delivered to Lee were the order that Lee had placed. On that basis, the Prosecution argued that Lee was in possession of the three bundles for the purpose of trafficking and could not rebut the statutory presumption. (Para 19)

Lee’s defence was that he had ordered only three half-pound packets of heroin, but that because of a mistake by the supplier he was given three one-pound packets instead. This was the foundation of his claim that he had not intended to traffic in the full quantity found in the bundles. The court later examined the timing, consistency, and evidential support for this claim in detail. (Para 21)

Yap’s evidence was different in emphasis. He said he did not know what kind of drugs he was collecting at 28/30 Gul Avenue or the quantity of those drugs, and that he did not ask Lee any questions. That evidence did not affirmatively support Lee’s oversupply theory; rather, it left Lee to prove his own account through the surrounding evidence. (Para 25)

"As against Lee, the Prosecution’s case is that he was in possession of the Three Bundles for the purpose of trafficking. As set out in the Statement of Agreed Facts, Lee had ordered heroin from his drug supplier, and the Three Bundles that had been collected by Yap and delivered to Lee was his order of heroin." — Per Ang Cheng Hock J, Para 19

"Lee’s case is that he only ordered three half-pound packets of heroin, but because of a mistake on the part of the drug supplier, he was given three one-pound packets instead." — Per Ang Cheng Hock J, Para 21

"However, his evidence is that he neither knew what kind of drugs he was collecting at 28/30 Gul Avenue nor the quantity of those drugs, and he did not ask Lee any questions." — Per Ang Cheng Hock J, Para 25

Why Did the Court Reject Lee’s Defence of Mistaken Oversupply?

The court’s rejection of Lee’s defence rested first on timing and consistency. The judge found that Lee’s claim of being oversupplied with heroin was only raised for the first time in his Case for Defence filed on 14 June 2021. That late emergence mattered because it meant the defence was not mentioned in his cautioned statement and was not part of the earliest account he gave to investigators. (Para 51)

The court then examined the evolution of Lee’s account and found that his shifting versions undermined his credibility. The judge observed that Lee’s exculpatory claim changed from the time of the Case for Defence, to the Amended Case for Defence, and finally during oral testimony. The court treated this as a serious credibility problem, especially because the defence depended on Lee’s own account of what he had ordered and what he believed he had received. (Para 58)

On the evidence as a whole, the judge was not satisfied that Lee had proved the facts necessary to show that he was not in possession of the three bundles for the purpose of trafficking. The court therefore held that the presumption in s 17(c) remained unrebutted and that the trafficking charge was made out beyond reasonable doubt. (Para 82)

"Lee’s claim that he had been oversupplied heroin by mistake was only raised for the first time in his Case for Defence (‘the CFD’) filed on 14 June 2021." — Per Ang Cheng Hock J, Para 51

"Lee’s shifting accounts about his exculpatory claim (from the time of the CFD, then the ACFD, and finally during his oral testimony) undermines his credibility as a witness." — Per Ang Cheng Hock J, Para 58

"On the evidence as a whole, I am not satisfied that Lee has done so." — Per Ang Cheng Hock J, Para 82

How Did the Court Use Lee’s Statements and Lies to Assess Credibility?

The court placed significant weight on Lee’s failure to mention the oversupply defence when his cautioned statement was recorded. The judge held that a material fact relied on at trial should have been stated in the cautioned statement, and that the omission allowed the court to draw an adverse inference. The court also noted that Lee had maintained a false account in his investigation statements, which further damaged his credibility. (Para 50)

The judge went further and described those lies as deliberate, reasoning that they must have been told because Lee realised that telling the truth would link him to the charge concerning the three bundles. The court relied on authority to support the proposition that lies may be used not only as corroboration of guilt but also as a basis for finding that an accused is not creditworthy, even if there is an explanation for the lie. (Para 51)

This credibility analysis was not merely ancillary. It formed part of the chain of reasoning by which the court concluded that Lee’s late oversupply defence was not believable and that the statutory presumption of trafficking had not been displaced. (Paras 50, 51, 82)

"In my judgment, Lee’s failure to mention his exculpatory claim when his cautioned statement came to be recorded, and the lie which he made in that statement and kept up with in his investigation statements, detrimentally affect his credibility and allows the court to draw an adverse inference that the version of events which he testified on is not the truth." — Per Ang Cheng Hock J, Para 51

"Surely, these lies must have been told out of Lee’s realisation that, if he had told the truth to the CNB officers, that would link him to the charge relating to the Three Bundles (see Ilechukwu Uchechukwu Chukwudi v Public Prosecutor [2021] 1 SLR 67 at [152]‒[156])." — Per Ang Cheng Hock J, Para 51

"a lie that is not corroborative of guilt can still be relied upon by the court to make a finding that an accused person is not creditworthy, even if the accused person had a valid explanation for lying" — Per Ang Cheng Hock J, Para 51

What Objective Evidence Did the Court Consider, and Why Was It Insufficient for Lee?

The court considered the call trace report for Phone A9, which showed a call to a Malaysian number identified as Kelvin’s number at 9.59pm lasting 3 minutes and 41 seconds. Lee relied on this call as part of his attempt to show that he had been speaking to Kelvin about an oversupply of heroin. The judge accepted the existence of the call but not the inference Lee sought to draw from it. (Para 59)

The court held that there was simply insufficient evidence to show that Lee was speaking to Kelvin about an oversupply of heroin during that call. The objective record did not establish the subject matter of the conversation, and the court was not prepared to infer from the call alone that Lee had discovered an oversupply and was discussing it with Kelvin. This was an important evidential gap because the oversupply defence depended heavily on Lee’s own narrative of how and when he learned of the alleged mistake. (Para 72)

In addition, the court accepted evidence that heroin is typically sold by Malaysia-based suppliers to Singapore-based traffickers in one-pound packets, referred to as “batus.” That evidence cut against Lee’s claim that he had ordered half-pound packets and was mistakenly supplied with one-pound packets, because it showed that one-pound packets were the ordinary commercial unit in the relevant drug trade. (Para 74)

"The Call Trace Report for Phone A9 indeed shows a phone call being made to a Malaysian number (which, as it is undisputed, is Kelvin’s number) at 9.59pm, and which lasted 3 minutes and 41 seconds." — Per Ang Cheng Hock J, Para 59

"There is simply insufficient evidence to show that Lee was speaking to Kelvin about an oversupply of heroin during that call." — Per Ang Cheng Hock J, Para 72

"His evidence is that heroin is typically sold by Malaysia-based suppliers to Singapore-based traffickers in one-pound packets, which are referred to as ‘batus’." — Per Ang Cheng Hock J, Para 74

How Did the Court Apply the Trafficking Presumption Under s 17(c) of the MDA?

The court treated the presumption in s 17(c) as the decisive statutory mechanism once possession of more than 2 grammes of diamorphine was established. The judge explained that the Prosecution could rely on the presumption if possession and knowledge were proved, and that the accused then bore the legal burden of proving facts showing that the possession was not for trafficking. (Paras 19, 37, 82)

In Lee’s case, the court found that he had not discharged that burden. The judge expressly rejected the credibility of Lee’s evidence that he intended to traffic only in three “halves” of heroin, and held that the evidence before the court did not support the proposition that the three bundles were an accidental oversupply. Because Lee failed to rebut the presumption, the court held that the elements of the trafficking charge were proved beyond reasonable doubt. (Para 82)

The court’s reasoning therefore linked the statutory presumption, the credibility findings, and the objective evidence into a single conclusion: Lee’s account did not displace the inference that he possessed the three bundles for trafficking. (Paras 37, 51, 72, 82)

"As such, the Prosecution can rely on (as they seek to) the presumption of trafficking in s 17(c) of the MDA (see Zainal bin Hamad v Public Prosecutor and another appeal [2018] 2 SLR 1119 at [49])." — Per Ang Cheng Hock J, Para 37

"In order for Lee to rebut the presumption of trafficking under s 17(c) of the MDA, the legal burden is on him to prove, on a balance of probabilities, the existence of facts which show that he was not in possession of the Three Bundles for the purpose of trafficking" — Per Ang Cheng Hock J, Para 82

"In short, I do not find Lee’s evidence that he only intended to traffic in three ‘halves’ of heroin to be credible." — Per Ang Cheng Hock J, Para 82

What Did the Court Say About Possession, Knowledge, and the Nature of the Drug?

The court restated the established elements of trafficking under s 5(1)(a) of the MDA: the Prosecution must prove possession of a controlled drug, knowledge of the nature of the controlled drug, and possession for the purpose of trafficking, which may be proved or presumed under s 17. The judge cited authority for the proposition that knowledge of quantity is an issue going to possession, not a separate element of trafficking in the way Lee sought to use it. (Paras 33, 35)

In discussing Lee’s position, the court noted that if Lee knew the three bundles were each one-pound packets of heroin, then there could be no dispute that he was in knowing possession of the entire quantity of heroin contained in the bundles, because he knew he had physical possession, custody, or control of those packets. The court therefore treated Lee’s alleged misunderstanding about quantity as insufficient to displace the legal consequences of his possession. (Para 35)

This analysis mattered because Lee’s defence was framed around the quantity he thought he had ordered. The court’s answer was that, even if quantity was relevant to his subjective understanding, the evidence did not establish the factual premise of his claim, and in any event the trafficking presumption remained unrebutted. (Paras 35, 82)

"In order to make out the charge of trafficking under s 5(1)(a) of the MDA, it is well established that the Prosecution must prove that the accused … (a) was in possession of a controlled drug … (b) had knowledge of the nature of the controlled drug … and (c) possessed the controlled drug for the purpose of trafficking which was not authorised, which may either be proved or presumed pursuant to s 17 of the MDA." — Per Ang Cheng Hock J, Para 33

"his defence is not about his knowledge of the quantity of transacted drugs, which is otherwise an issue going to the question of possession" — Per Ang Cheng Hock J, Para 35

"given Lee’s knowledge that the Three Bundles were each one-pound packets of heroin, there can be no dispute that Lee was in ‘knowing possession’ of the entire quantity of heroin contained in the Three Bundles, given that he knew that he had physical possession, custody or control of those three one-pound packets" — Per Ang Cheng Hock J, Para 35

How Did Yap’s Evidence Affect the Court’s Assessment of Lee’s Defence?

Yap’s evidence did not rescue Lee’s case. Although Yap accepted that he had collected drugs at Lee’s instructions and delivered them to the hotel room, he said he did not know what kind of drugs he was collecting or how much there was, and he did not ask Lee any questions. That meant Yap could not provide direct support for Lee’s claim that the supplier had mistakenly oversupplied him. (Para 25)

The court therefore treated Yap’s evidence as neutral at best and potentially inconsistent with any suggestion that Yap was aware of an oversupply issue. The judge’s reasoning indicates that the defence could not rely on Yap to fill the evidential gap in Lee’s account, especially where Lee’s own testimony was late and inconsistent. (Paras 25, 58, 72)

As a result, the court’s treatment of Yap was largely instrumental to the analysis of Lee’s guilt: Yap’s role established the chain of delivery, but his evidence did not establish the mistaken-oversupply narrative that Lee needed. (Paras 8, 10, 25, 82)

"However, his evidence is that he neither knew what kind of drugs he was collecting at 28/30 Gul Avenue nor the quantity of those drugs, and he did not ask Lee any questions." — Per Ang Cheng Hock J, Para 25

"As for Yap, it is undisputed, and it is also his evidence at the trial that he had agreed to collect drugs from 28/30 Gul Avenue at Lee’s instructions and deliver them to Lee at the Room in the Hotel, and that the Three Bundles were part of these drugs …" — Per Ang Cheng Hock J, Para 38

Why Did the Court Convict Lee?

The conviction followed from the court’s rejection of Lee’s factual account and its application of the statutory presumption. The judge found that Lee had not rebutted the presumption in s 17(c) that he possessed the three bundles for the purpose of trafficking, and that the evidence established the offence under s 5(1)(a) read with s 5(2) beyond reasonable doubt. (Para 82)

The court’s reasoning was cumulative rather than single-factor. It relied on the late emergence of the oversupply defence, the inconsistency of Lee’s accounts, the adverse inference from his cautioned statement and investigation statements, the lack of objective support from the phone records, and the absence of corroboration from Yap. Taken together, these factors led the judge to reject Lee’s evidence as not credible. (Paras 50, 51, 58, 59, 72, 82)

The final holding was therefore not merely that Lee had failed to persuade the court on a factual dispute. It was that, on the evidence before the court, the legal burden imposed by s 17(c) had not been discharged, and the trafficking charge was proved beyond reasonable doubt. (Para 82)

"Lee’s claim of being oversupplied with drugs was only raised late in the day, and he has not been able to maintain a consistent account of how he learnt that he was oversupplied with drugs." — Per Ang Cheng Hock J, Para 82

"Accordingly, I find that the elements of the trafficking charge under s 5(1)(a) read with s 5(2) of the MDA against Lee have been proven beyond reasonable doubt, and I convict him accordingly." — Per Ang Cheng Hock J, Para 82

Why Does This Case Matter?

This case is important because it shows how a trafficking defence based on alleged mistaken oversupply will be tested against the accused’s earliest statements, the consistency of later pleadings, and the objective evidence. The judgment demonstrates that a late-arising defence, especially one that changes over time, may be treated as unreliable even before the court reaches the statutory presumption analysis. (Paras 50, 51, 58, 82)

It also illustrates the practical operation of s 17(c) of the MDA in a prosecution involving a substantial quantity of diamorphine. Once the Prosecution established the factual foundation for possession, the accused had to prove facts showing that the drugs were not possessed for trafficking. The court’s reasoning makes clear that bare assertion is not enough; the defence must be supported by coherent, consistent, and preferably objective evidence. (Paras 19, 37, 72, 82)

For practitioners, the case underscores the evidential significance of cautioned statements, investigation statements, and phone records in drug-trafficking trials. It also shows that a co-accused’s evidence may be insufficient if it does not directly corroborate the accused’s own exculpatory narrative. (Paras 50, 51, 59, 72, 82)

Cases Referred To

Legislation Referenced

• Misuse of Drugs Act (Cap 185, 2008 Rev Ed): s 5(1)(a), s 5(2), s 17(c), s 18(1)(a), s 18(2), s 33(1), s 33B (Paras 1, 18, 19, 31, 32, 82) [CDN] [SSO]
• Criminal Procedure Code (Cap 68, 2012 Rev Ed): s 23, s 261(1) (Para 50)

Source Documents

• Original Judgment — Singapore Courts
• Archived Copy (PDF) — Litt Law CDN

This article analyses [2022] SGHC 199 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the full judgment for the Court's complete reasoning.