THE LAW SOCIETY OF SINGAPORE v WILLJUDE VIMALRAJ S/O RAYMOND SURAS

"We are amply satisfied that due cause has been shown for the respondent to be struck off the Roll." — Per Sundaresh Menon CJ, Para 12

Case Information

• Citation: [2026] SGHC 22 (Para heading / front matter)
• Court: Court of 3 Supreme Court Judges (Para heading / front matter)
• Date of hearing: 22 January 2026 (Para heading / front matter)
• Coram: Sundaresh Menon CJ, Belinda Ang Saw Ean JCA, and Hri Kumar Nair JCA (Para heading / front matter)
• Counsel for the applicant: Ramesh s/o Selvaraj, Jonathan Kenric Trachsel, and Bay Jia Wei (Allen & Gledhill LLP) (Para end)
• Counsel for the respondent: Xu Daniel Atticus (Exodus Law Corporation) (Para end)
• Case number: Originating Application No 1 of 2025 (Para heading / front matter)
• Area of law: Legal Profession — Disciplinary proceedings (Para heading / front matter)
• Judgment delivered ex tempore by Sundaresh Menon CJ for the court (Para 1)

Summary

The Law Society of Singapore applied under the Legal Profession Act 1966 (2020 Rev Ed) to strike the respondent off the Roll after his criminal convictions for forgery and intentionally giving false evidence. The court accepted that the respondent’s offences involved dishonesty at their core and that, in disciplinary proceedings of this kind, striking off is the presumptive sanction unless truly exceptional facts make that outcome disproportionate. The court therefore concluded that due cause had been shown and ordered that the respondent be struck off. (Para 1, Para 12, Para 13, Para 21)

The respondent had been admitted as an Advocate and Solicitor on 10 February 2021, but the offending conduct occurred earlier, between 30 November 2018 and 21 January 2019, when he was serving as an Investigating Officer in the Singapore Police Force. He later made a false statement in his admission affidavit dated 22 December 2020, despite knowing that he was under criminal investigation, and he was convicted on 20 June 2024 of nine forgery charges and one false evidence charge. The court treated the dishonesty as integral to the offences and found that the date of commission did not prevent striking off under s 83(2)(a) of the LPA. (Para 3, Para 4, Para 5, Para 6, Para 16)

The court also considered whether s 16(4) of the LPA, which mandates striking off where an admission affidavit contains a substantially false statement or suppression of a material fact, had any bearing on the case. It observed that s 16(4) could apply because the respondent’s admission affidavit contained a materially false statement, but it did not need to rely on that provision because due cause was already established under the disciplinary regime. The court rejected the respondent’s asserted mitigating circumstances, including his diagnosis of Major Depressive Disorder and the absence of monetary gain, and ordered costs in favour of the Law Society. (Para 15, Para 19, Para 20, Para 22)

Why did the court say due cause had been shown for striking the respondent off the Roll?

The court’s central conclusion was stated in direct and emphatic terms: “We are amply satisfied that due cause has been shown for the respondent to be struck off the Roll.” That conclusion was reached after the court examined the respondent’s convictions, the dishonest character of the offences, and the disciplinary principles governing solicitors convicted of offences involving fraud or dishonesty. The court treated the matter as one in which the integrity of the profession and the protection of the public were paramount. (Para 12, Para 13, Para 20)

"Misconduct involving dishonesty will almost invariably lead to an order for striking off where the dishonesty reveals a character defect rendering the errant solicitor unsuitable to be a member of the profession or that threatens to undermine the administration of justice." — Per Sundaresh Menon CJ, Para 13

That principle was decisive because the respondent’s convictions were not for technical or peripheral wrongdoing; they were for forgery and intentionally giving false evidence, both of which the court treated as inherently dishonest. The court reasoned that dishonesty of this kind ordinarily demonstrates a character defect incompatible with continued membership of the profession, especially where the solicitor had occupied a position of public trust. The court therefore regarded striking off as the presumptive sanction, absent truly exceptional facts. (Para 13, Para 14, Para 19)

The court also made clear that the respondent had not shown any exceptional circumstances capable of displacing that presumption. It expressly agreed with the Law Society that there were “no exceptional circumstances at all” suggesting that striking off would be disproportionate or otherwise inappropriate. In the court’s view, the seriousness of the dishonesty, the respondent’s role as an Investigating Officer, and the false statement in his admission affidavit all pointed in the same direction: the public needed protection, and confidence in the profession had to be maintained. (Para 19, Para 20, Para 21)

What were the respondent’s convictions and why did they matter in the disciplinary proceedings?

The respondent’s criminal convictions were the foundation of the disciplinary application. The court recorded that on 20 June 2024 he pleaded guilty to and was convicted of ten charges: nine charges of forgery under s 463 of the Penal Code, punishable under s 465, and one charge of intentionally giving false evidence in a judicial proceeding, punishable under s 193 of the Penal Code. The respondent also consented to 29 other forgery charges being taken into consideration for sentencing. (Para 4, Para 7)

"On 20 June 2024, he pleaded guilty to and was convicted of ten charges, comprising (a) nine charges of forgery under s 463 of the Penal Code (Cap 224, 2008 Rev Ed) (the “Penal Code”), punishable under s 465 (the “forgery charges”); and (b) one charge of intentionally giving false evidence in a judicial proceeding, punishable under s 193 of the Penal Code (the “false evidence charge”)." — Per Sundaresh Menon CJ, Para 4

Those convictions mattered because the Law Society’s application was brought under ss 94A(1) and 98(1) of the LPA on the basis that the respondent had been convicted of offences involving fraud or dishonesty. The court accepted that the offences were not merely criminal in the abstract; they were disciplinary in significance because they went directly to the respondent’s fitness to practise. The judgment treated the convictions as proof of due cause under the statutory framework, especially given the dishonesty inherent in the offences. (Para 1, Para 11, Para 13)

The court also noted the sentence imposed in the criminal proceedings: an aggregate term of 25 months’ imprisonment with effect from 18 July 2024. While the disciplinary court did not re-sentence the respondent, the criminal sentence underscored the seriousness of the conduct and the gravity with which the criminal courts had viewed it. The disciplinary analysis then proceeded on the separate question of professional fitness, where the same conduct was even more damaging because it implicated trust, honesty, and the administration of justice. (Para 8, Para 19, Para 20)

How did the respondent’s conduct before admission affect the court’s analysis?

A key feature of the case was that the offences were committed before the respondent’s admission as an Advocate and Solicitor on 10 February 2021. The court recorded that the offending conduct took place between 30 November 2018 and 21 January 2019, when the respondent was serving as an Investigating Officer in the Singapore Police Force. The respondent had forged witness statements that he was required to record in the course of investigations into various criminal matters. (Para 3, Para 5)

"The respondent was an Investigating Officer (“IO”) in the Singapore Police Force (“SPF”) when he forged witness statements he had been required to record in the course of his investigations into various criminal matters." — Per Sundaresh Menon CJ, Para 5

The court did not treat the pre-admission timing as a barrier to striking off. It expressly stated that the date of commission of the offences was irrelevant for the purposes of striking off under s 83(2)(a) of the LPA. What mattered was that the respondent had been convicted of offences implying a defect of character that made him unfit for the profession. The court therefore rejected any suggestion that the fact that the conduct predated admission insulated the respondent from disciplinary consequences. (Para 16, Para 11)

At the same time, the pre-admission timing became relevant in a different way: the respondent had already been under investigation when he completed his admission affidavit. The court found that he knew the affidavit statement was false when he declared that he was not the subject of any pending investigation or proceedings. That falsehood was especially serious because it was made in the context of admission to the profession, where candour is essential. The court therefore considered the pre-admission conduct and the admission affidavit together as part of a continuous pattern of dishonesty. (Para 6, Para 14, Para 15)

Why did the court place weight on the false statement in the respondent’s admission affidavit?

The respondent’s admission affidavit was a major aggravating feature. The court found that despite knowing he was under investigation, he declared in his admission affidavit dated 22 December 2020 that he was not “the subject of any pending investigation or proceedings in Singapore or elsewhere in respect of any criminal offence,” when he was legally bound to state the truth. The court also noted that he had been served with a Notice of Investigation on 21 February 2019 and had signed and acknowledged it on 26 February 2019. (Para 6)

"Despite this knowledge, he declared in his admission affidavit dated 22 December 2020 that he was not ‘the subject of any pending investigation or proceedings in Singapore or elsewhere in respect of any criminal offence’, when he was legally bound to state the truth." — Per Sundaresh Menon CJ, Para 6

The court observed that s 16(4) of the LPA states that the name of an Advocate and Solicitor “must be struck off” if, after admission, it is shown that any affidavit filed by them contains any substantially false statement or suppression of a material fact. The court said that s 16(4) could apply in this case because the respondent’s admission affidavit contained a substantially false statement. It also relied on authorities indicating that the falsity crossed the de minimis threshold of materiality and that criminal investigations would undoubtedly have affected admission to the Bar. (Para 15)

Even so, the court did not need to decide the case solely under s 16(4). Instead, it treated the false affidavit as reinforcing the seriousness of the respondent’s dishonesty and as confirming that the respondent’s conduct went to the heart of professional integrity. The court’s reasoning was that a person who lies in an admission affidavit about pending criminal investigations demonstrates a serious character defect, and that such a defect is especially incompatible with the role of an Advocate and Solicitor. (Para 15, Para 18, Para 20)

How did the court interpret s 83(2)(a) of the Legal Profession Act?

The court relied on s 83(2)(a) of the LPA, which provides that due cause may be shown by proof that an advocate and solicitor has been convicted of a criminal offence implying a defect of character that makes him or her unfit for the profession. The court quoted that provision and then applied it to the respondent’s convictions for forgery and intentionally giving false evidence. The statutory focus was on the conviction and the character implications of the offence, not on the date when the underlying conduct occurred. (Para 11, Para 16)

"Section 83(2)(a) of the LPA states that ‘due cause may be shown by proof that an advocate and solicitor has been convicted of a criminal offence, implying a defect of character which makes him or her unfit for his or her profession’." — Per Sundaresh Menon CJ, Para 11

The court then made a specific interpretive point: “The date of the commission of the respondent’s offences is however irrelevant for the purposes of striking off under s 83(2)(a) of the LPA.” That statement was important because it answered the respondent’s potential reliance on the fact that the offences were committed before admission. The court’s approach was that the disciplinary consequence flows from the conviction and the character defect it reveals, not from a temporal comparison between the offence date and the admission date. (Para 16)

On that basis, the court concluded that the respondent’s pre-admission conduct did not prevent the application of s 83(2)(a). Instead, the conviction after admission, coupled with the dishonesty inherent in the offences, established due cause. The court then moved to the sanction question and held that striking off was the appropriate response because the case involved serious dishonesty and no exceptional circumstances. (Para 16, Para 18, Para 19, Para 21)

What did the court say about dishonesty, forgery, and the presumptive sanction of striking off?

The court treated dishonesty as the central feature of the respondent’s misconduct. It stated that “the dishonesty is clearly integral to the commission of the respondent’s offences,” and it relied on authority for the proposition that forgery is dishonesty. The court’s reasoning was that the offences were not merely technically unlawful; they were fundamentally dishonest acts that undermined the administration of justice and the trust placed in legal professionals. (Para 14)

"The dishonesty is clearly integral to the commission of the respondent’s offences." — Per Sundaresh Menon CJ, Para 14

The court also cited Law Society of Singapore v Jaya Anil Kumar for the proposition that forgery is dishonesty. That citation was used to reinforce the obvious point that the respondent’s forgery convictions were squarely within the category of offences that ordinarily justify the most serious disciplinary response. The court’s analysis therefore linked the criminal law characterisation of the offences with the professional discipline consequence. (Para 14)

In addition, the court invoked Law Society of Singapore v Chia Choon Yang to state that striking off will be the presumptive sanction unless there are truly exceptional facts showing that striking off would be disproportionate, which will be extremely rare. The court then applied that principle to the respondent’s case and found no such exceptional facts. The result was that the presumptive sanction remained intact and was in fact the appropriate sanction. (Para 13, Para 19)

Why did the court reject the respondent’s asserted mitigating circumstances?

The respondent advanced circumstances that he said should mitigate the disciplinary outcome, including his diagnosis of Major Depressive Disorder and the absence of monetary gain from the offences. The court rejected those submissions. It stated that the circumstances cited by the respondent “are not mitigating,” and it explained why each point failed to displace the need for striking off. (Para 19)

"The circumstances cited by the respondent both at the hearing and in his written submissions are not mitigating." — Per Sundaresh Menon CJ, Para 19

As to the diagnosis of Major Depressive Disorder, the court said there was no evidence to suggest that the diagnosis caused the respondent to make a false statement in his admission affidavit. That was a critical point because the false affidavit was one of the most serious aspects of the case. Without evidence of causation, the diagnosis could not explain or excuse the dishonesty. The court therefore refused to treat the diagnosis as a mitigating factor in the disciplinary sense. (Para 19)

As to the absence of monetary gain, the court said that this was wholly irrelevant given the serious harm caused to the administration of justice. The court emphasised that the respondent had been entrusted with significant public power as an Investigating Officer, and that forging witness statements represented a fundamental breach of that trust. The disciplinary concern was not whether the respondent profited financially, but whether his conduct demonstrated a character defect incompatible with the profession and threatened public confidence. (Para 19, Para 20)

How did the court distinguish disciplinary mitigation from criminal mitigation?

The court made an important doctrinal point about the role of mitigation in disciplinary proceedings. It observed that mitigating factors are not treated in the same way in disciplinary proceedings as they are in criminal proceedings because the principal purpose of disciplinary sanctions in the professional setting is to protect the public and uphold confidence in the integrity of the legal profession. That principle meant that personal hardship, lack of gain, or other criminal-sentencing considerations could not carry the same weight in the disciplinary context. (Para 20)

"Mitigating factors are not treated in the same way in disciplinary proceedings as they are in criminal proceedings, because the principal purpose of disciplinary sanctions in the professional setting is to protect the public and uphold confidence in the integrity of the legal profession: Chia Choon Yang at [17]." — Per Sundaresh Menon CJ, Para 20

Applying that principle, the court concluded that the respondent’s asserted mitigation did not answer the real question: whether the public could safely be entrusted with a solicitor who had committed serious acts of dishonesty and then lied in his admission affidavit. The court’s answer was no. The disciplinary process was not designed to reward remorse or reduce sanction merely because the respondent did not obtain monetary gain; it was designed to protect the public and the profession’s reputation. (Para 19, Para 20)

The court therefore treated the respondent’s mitigation arguments as legally insufficient rather than merely factually weak. The absence of exceptional circumstances, combined with the seriousness of the dishonesty, meant that the ordinary disciplinary response had to follow. That response was striking off, not suspension or a lesser sanction. (Para 19, Para 20, Para 21)

What did the court say about s 16(4) of the LPA and the false admission affidavit?

The court expressly considered s 16(4) of the LPA, which states that the name of an Advocate and Solicitor “must be struck off” if it is shown to the satisfaction of the court, at any time after admission, that any affidavit filed by them contains any substantially false statement or a suppression of any material fact. The court noted that this provision could apply because the respondent’s admission affidavit contained a substantially false statement about pending investigations. (Para 15)

"Section 16(4) states that the name of an Advocate and Solicitor ‘must be struck off’ the Roll if it is shown to the satisfaction of the court, at any time after their admission, that any affidavit filed by them ‘contains any substantially false statement or a suppression of any material fact’." — Per Sundaresh Menon CJ, Para 15

The court further observed that the falseness of the statement was substantial and crossed the de minimis threshold of materiality, citing Attorney-General v Phua Jill. It also referred to Attorney-General v Shahira Banu for the proposition that s 16(4) could apply where an admission affidavit contains a substantially false statement, and to Re Mohamad Shafee Khamis as an example that criminal investigations would undoubtedly have affected admission to the Bar. These references supported the court’s view that the false affidavit was not a trivial irregularity but a serious breach of candour. (Para 15)

However, the court did not rest its decision on s 16(4). Instead, it said it was sufficient to decide the case under the disciplinary provisions because due cause had already been shown under s 83(2)(a). The court’s treatment of s 16(4) therefore served to reinforce the seriousness of the respondent’s conduct and to show that, even on a separate statutory route, the same conduct would have been deeply problematic. (Para 15, Para 21)

What role did the respondent’s position as an Investigating Officer play in the court’s reasoning?

The respondent’s role as an Investigating Officer in the Singapore Police Force was not a neutral background fact; it was central to the court’s assessment of seriousness. The court noted that he was entrusted with significant public power in order to discharge his responsibilities as an IO, and that when he forged witness statements, he demonstrated a fundamental breach of that trust. That breach made the dishonesty more serious because it occurred in the performance of public duties connected to the administration of justice. (Para 5, Para 19)

"As the Law Society emphasises in its written submissions, the respondent was entrusted with significant public power in order to discharge his responsibilities as an IO, and when he forged witness statements, he demonstrated a fundamental breach of that trust." — Per Sundaresh Menon CJ, Para 19

The court’s reasoning shows that the respondent’s professional background aggravated rather than softened the misconduct. A person who has access to investigative powers and then falsifies witness statements does not merely commit a private wrong; he undermines the integrity of the criminal justice process. That is why the court linked the conduct to the administration of justice and to public confidence in the legal profession. (Para 5, Para 13, Para 19)

This feature also helped explain why the court rejected the absence of monetary gain as a mitigating factor. The harm lay not in financial enrichment but in the corruption of official process and the betrayal of public trust. The court therefore treated the respondent’s former role as an aggravating context that made striking off all the more necessary. (Para 19, Para 20)

What orders did the court make at the end of the case?

The court’s final order was that the respondent be struck off the Roll. It stated: “Therefore, due cause has been shown for the respondent to be struck off the Roll, and we so order.” That was the substantive disciplinary outcome and the culmination of the court’s analysis of dishonesty, conviction, statutory interpretation, and mitigation. (Para 21)

"Therefore, due cause has been shown for the respondent to be struck off the Roll, and we so order." — Per Sundaresh Menon CJ, Para 21

The court also ordered costs in favour of the Law Society. It fixed costs at $6,000 and disbursements at $1,110.75, describing the amount claimed as reasonable. The costs order reflected the fact that the Law Society had succeeded in the application and that the matter had been straightforward in principle once the convictions and dishonesty were established. (Para 22)

The result was therefore complete professional removal, together with an adverse costs order. The judgment left no ambiguity that the respondent’s conduct was incompatible with continued practice as an Advocate and Solicitor. The court’s orders were consistent with its broader emphasis on public protection and the maintenance of confidence in the legal profession. (Para 21, Para 22)

Why does this case matter for disciplinary law and professional regulation?

This case matters because it reaffirms that dishonesty-related convictions will ordinarily lead to striking off, especially where the dishonesty is integral to the offences and there are no truly exceptional facts. The court’s reliance on Chia Choon Yang confirms that striking off remains the presumptive sanction in serious dishonesty cases, and that mitigation has limited force in the disciplinary setting. For practitioners, the case is a clear reminder that the profession treats honesty as a foundational requirement, not a negotiable virtue. (Para 13, Para 20)

The case also matters because it clarifies that the timing of the underlying conduct does not necessarily save a solicitor from disciplinary consequences if the conviction occurs after admission. The court’s statement that the date of commission is irrelevant under s 83(2)(a) is significant for future cases involving pre-admission misconduct discovered only later. It means that the disciplinary focus remains on the conviction and the character defect it reveals, rather than on formal chronology alone. (Para 16, Para 18)

Finally, the case is important because it shows how s 16(4) of the LPA may overlap with the disciplinary regime where an admission affidavit contains a materially false statement. Even though the court did not need to decide the case under s 16(4), its observations indicate that falsehoods in admission documents are treated with exceptional seriousness. The decision therefore strengthens the message that candour at the point of admission is indispensable and that dishonesty at that stage can have career-ending consequences. (Para 15, Para 21)

Cases Referred To

Legislation Referenced

• Legal Profession Act 1966 (2020 Rev Ed): ss 94A(1), 98(1), 83(1)(a), 83(2)(a), 83(2)(h), 83(6), 16(4) (Para 1, Para 11, Para 15)
• Penal Code (Cap 224, 2008 Rev Ed): ss 463, 465, 193 (Para 4)

"The respondent was sentenced to an aggregate term of 25 months’ imprisonment with effect from 18 July 2024." — Per Sundaresh Menon CJ, Para 8

"The respondent asserted in his admission affidavit that he was not subject to any criminal investigations in Singapore although he knew this to be untrue (see above at [6])." — Per Sundaresh Menon CJ, Para 14

"By contrast, the respondent’s conviction took place after his admission to the Bar, and its nature is such that it reveals a serious character defect that brings the need for the protection of the public to the fore." — Per Sundaresh Menon CJ, Para 18

"We also agree with the Law Society that there are no exceptional circumstances at all that would suggest that a striking off order would be disproportionate or otherwise inappropriate." — Per Sundaresh Menon CJ, Para 19

"The falseness of the statement was substantial and crossed the de minimis threshold of materiality: Attorney-General v Phua Jill [2024] SGHC 214 (‘Jill Phua’) at [10], for the following reasons." — Per Sundaresh Menon CJ, Para 15

"The respondent knew that his statement in his admission affidavit was false (see above at [6]) and the fact that he was subject to criminal investigations would undoubtedly have affected his admission to the Bar: see, for example, Re Mohamad Shafee Khamis [2024] 6 SLR 173." — Per Sundaresh Menon CJ, Para 15

"The respondent was admitted as an Advocate and Solicitor of the Supreme Court of Singapore on 10 February 2021." — Per Sundaresh Menon CJ, Para 3

"The offences took place between 30 November 2018 and 21 January 2019, which was before the date of his admission as an Advocate and Solicitor of the Supreme Court." — Per Sundaresh Menon CJ, Para 5

Source Documents

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

This article analyses [2026] SGHC 22 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the full judgment for the Court's complete reasoning.