Life imprisonment in Singapore

Life imprisonment is a legal penalty in Singapore. This sentence is applicable for more than forty offences under Singapore law (including the Penal Code, the Kidnapping Act and Arms Offences Act), such as culpable homicide not amounting to murder, attempted murder (if hurt was caused), kidnapping by ransom, criminal breach of trust by a public servant, voluntarily causing grievous hurt with dangerous weapons, and trafficking of firearms, in addition to caning or a fine for certain offences that warrant life imprisonment.
From 1 January 2013 onwards, the amendments to the death penalty laws in Singapore allow judges to impose life imprisonment as the lowest punishment for capital drug trafficking and murder with no intention to kill, under certain conditions for eligibility. Despite the legal changes and increasing cases of life imprisonment for murder and drug crimes, Law Minister K. Shanmugam revealed in 2020 that through two public surveys on Singaporeans and non-Singaporeans, more than 80% of both groups responded that the death penalty is more effective than life imprisonment as a deterrent towards capital offences.
Since 20 August 1997, after the landmark appeal of Abdul Nasir Amer Hamsah, the definition of life imprisonment is changed to mean a term of incarceration for the rest of a convict's natural lifespan, although it carries a possibility of release on parole after a minimum period of 20 years behind bars based on the prisoner's conduct.
The most recent case of life imprisonment in Singapore was that of 46-year-old Heng Boon Chai, who was found guilty of murdering his 46-year-old neighbour at Punggol in 2021. Heng was sentenced to life imprisonment (plus ten strokes of the cane) on 7 November 2024.
Since the British colonial period of Singapore, the laws of Singapore was enacted based on the laws of England, and life imprisonment was thus included as one of the legal penalties allowed for certain offences in Singapore, even after its independence from British colonial rule. In the past, the laws of Singapore decreed that life imprisonment was a fixed sentence of 20 years with the possibility of one-third remission of the sentence (13 years and 4 months) for good behaviour. This definition was recognised by the Court of Appeal in the judgement of Neo Man Lee, a schizophrenic killer who received a life term in 1989 for the 1984 case of culpable homicide of Judy Quek.
Extracted from Neo Man Lee v Public Prosecutor (1991):
In June 1993, a question over the definition of life imprisonment was raised during the trial of Tan Swee Hoon, who was one of the two perpetrators responsible for the 1985 murder of an Indonesian fish merchant Nurdin Nguan Song. After Tan, who was arrested for another crime in 1992, pleaded guilty to manslaughter and unrelated armed robbery charges, the prosecution argued that Tan should be sentenced to the maximum penalty of life imprisonment, and in response, Tan's defence counsel Michael Teo and Liew Chen Mine argued that Tan should not be jailed for the rest of his natural life and it would be unfair to have the other jail terms for armed robbery to run consecutively with a life sentence for manslaughter, and this led to the trial court inquiring the prosecution about whether life imprisonment was supposed to be a jail term of 20 years or the remainder of one's natural life. However, the prosecution did not reply, and instead, they changed their request for Tan to serve 20 years' preventive detention. In the end, 41-year-old Tan was sentenced to 23 years in prison and 24 strokes of the cane. On the other hand, Tan's accomplice Loh Yoon Seong was caught in 1988, and he was found guilty of murder and sentenced to death in 1990, Loh lost his appeal in 1991, and his execution was carried out on an unknown date after the end of Tan's trial.
Since then, the definition of life imprisonment was still considered as a jail term of 20 years, but it would eventually be amended with effect from 20 August 1997 due to a landmark appeal that significantly raised the question behind the meaning of life imprisonment.
On 20 August 1997, Abdul Nasir bin Amer Hamsah, a Singaporean who received a life sentence (20 years) for the kidnapping of two policemen and a consecutive 18-year sentence for a separate case of robbery with hurt, submitted an appeal for the two sentences to run concurrently, which would mean he only need to serve 20 years in jail rather than 38 years (with the two terms served consecutively) if successful. But the Court of Appeal dismissed Abdul Nasir's appeal and ordered that he be serving 38 years in jail like the trial judge ordered. However, the three-judge panel, led by Chief Justice Yong Pung How, decide that it would be wrong to consider life imprisonment as a fixed jail term of 20 years and thus changed the definition of life imprisonment to a term of imprisonment for the prisoner's remaining lifespan. The amended definition is thus retroactively applied to future crimes committed after 20 August 1997. Since Abdul Nasir was already sentenced prior to this appeal verdict, his life sentence remained as a 20-year jail term under the previous law's definition.
The appeal of Abdul Nasir, titled "Abdul Nasir bin Amer Hamsah v Public Prosecutor [1997] SGCA 38", was since regarded as a landmark in Singapore's legal history as it changed the definition of life imprisonment from "life" to "natural life" under the law. It also affected the future cases of life imprisonment that occurred after 20 August 1997, where criminals like Sundarti Supriyanto, Tony Anak Imba, Leslie Khoo Kwee Hock and Yong Vui Kong were sentenced to the current version of natural life imprisonment instead of the old "20 years" version of life imprisonment.
The ruling of Abdul Nasir's appeal, however, did not affect any outstanding cases that happened before the 1997 changes to the law, and the old life imprisonment laws is still applicable for these cases, where the offender would not be imprisoned for life but for at most twenty years. In the case of wanted gunman Chin Sheong Hon, who was arrested in 2013 for using a revolver to rob and hurt a woman back in November 1981, the trial judge Pang Khang Chau highlighted that life imprisonment, as the maximum penalty for Chin's crime, should not be a term that lasts the remainder of his natural life but a term of twenty years' jail under the old laws before Abdul Nasir's case, since his crime was committed in 1981 while the previous laws were still in effect back then. 72-year-old Chin, in the end, was sentenced to 18 years' imprisonment in November 2022 despite the prosecution's submissions for a life sentence.
On 1 January 2013, the government of Singapore approved the changes to the death penalty laws, in which they introduced life imprisonment as the minimum punishment for murder offences with no intention to kill and capital drug trafficking, under certain conditions. For offenders who commit murder but had no intention to kill, they would receive life sentences with caning. This discretion is similarly applied to those convicted of drug trafficking, provided that they only act as couriers, suffering from impaired mental responsibility (e.g. depression), and/or substantively assisting the authorities in disrupting drug-related activities. Drug traffickers who were suffering from diminished responsibility will serve a mandatory life sentence without caning for their crimes, while those who acted as couriers would receive life terms and caning of not less than 15 strokes.
Minister for Law K. Shanmugam stated that these changes were a right step taken in view of the extremely low crime rate and increasing rate of public safety in Singapore, and such changes were made to allow judges to have more discretion in deciding between death and life in capital cases where their individual circumstances did not sufficiently call for the death penalty, which allowed more emphasis on mercy during sentencing while maintaining the need for retribution and deterrence. Shanmugam also quoted in his own words, "Justice can be tempered with mercy and, where appropriate, offenders should be given a second chance".
These legal reforms allowed offenders in some capital cases to be sentenced to life imprisonment instead of death, and it also allowed some death row inmates (notably Cheong Chun Yin and Yong Vui Kong) to be given the chance to undergo re-sentencing and had their sentences commuted to life. There were also subsequent cases, notably the case of Kho Jabing, that coined the main sentencing guidelines for murder, where it specified the required factors for judges to consider before imposing either the death penalty or life imprisonment, and it influenced the judgements of several murder cases like Micheal Anak Garing, Boh Soon Ho, Leslie Khoo Kwee Hock, Chia Kee Chen and Azlin Arujunah.
On 14 March 1972, five men – Sia Ah Kew, Ho Kok Keng, Hoong Khung Cheong, Koo Ah Choo and Lim Chai Thiam – were involved in the kidnapping of Tjioe Kok Hwie, an affluent Indonesian businessman and they demanded from Tjioe's daughters and wife a ransom of S$50,000. The five kidnappers were later arrested and sentenced to death by two High Court judges Choor Singh and D. C. D'Cotta on charges of kidnapping by ransom, a crime which attracts either a death sentence or life imprisonment with/without caning under the Kidnapping Act.
After the end of their trial proceedings in October 1973, the five kidnappers filed their appeals for their death sentences to be reduced, and on 2 April 1974, the Court of Appeal, having duly considered the facts, decided to reduce the death sentences to life imprisonment for the kidnappers. In addition to their life sentences, the five men also received caning: out of the five, Ho received the highest number of 12 strokes of the cane, Hoong received nine while the remaining three were caned six strokes.
In their ruling, the three-judge panel, consisting of Wee Chong Jin, Frederick Arthur Chua and T. Kulasekaram, stated that despite the kidnappers being armed with pistols and daggers and had threatened Tjioe and his family, they did not cause physical harm to Tjioe and they treated him well while he was confined by the kidnappers. The judges were of the view that the death penalty should strictly be reserved for the worst cases of kidnapping and in cases where the circumstances did not signal an anxious need for capital punishment or spark an outrage of the community's feelings, life imprisonment (whether with caning or not) should be the default sentence for those convicted of kidnapping by ransom.
Extracted from Sia Ah Kew and Others v Public Prosecutor [1974]:
In the aftermath of the case, there were only five cases of kidnapping by ransom that took place between 1999 and 2014, though all cases ended with the courts issuing verdicts of life imprisonment based on the benchmark ruling and principles set by the Sia Ah Kew case, since all cases did not involve any serious harm caused to the victims. The rarity of kidnapping in Singapore was due to the tough laws and use of capital punishment in Singapore for the crime, and it was known to be an effective deterrent, resulting in kidnapping crimes being rarely committed in Singapore, as well as the judges' preference to sentence kidnappers to life in prison rather than death due to lack of aggravating circumstances that called for the death penalty.
In November 1996, 28-year-old cleaning supervisor Kelvin Lim Hock Hin was arrested by the police for allegations of sexual assault of five young boys between ages nine and 13, of which two of the victims were his godsons. He was investigated to have used offers of free tuition and toys to lure his victims and gain their trust before performing anal and oral sex on them. Prior to his arrest, Lim was convicted twice in 1988 and 1993 for sexual offences against young boys; his first sentence was 15 months' jail and the second was 32 months, and he was just released for less than four months before he re-offended. As Lim, who pleaded guilty to ten out of 40 charges of unnatural sex with a minor, was diagnosed with chronic paedophilia, a psychological sexual disorder where there is a sexual preference in young children, and Lim also had a high risk of re-offending, which persuaded Justice T. S. Sinnathuray to sentence Lim to a total of 40 years' imprisonment (consisting of four consecutive terms of ten years each) on 29 August 1997, to isolate him from society out of protection as long as possible. In fact, under the law back in 1997 before its eventual repeal, Section 377 of the Penal Code (the 1985 edition) decreed that a charge of unnatural sex with a minor carries the maximum sentence of life imprisonment, a sentence which Lim evaded.
In November 1997, in dismissing Kelvin Lim's appeal, the Court of Appeal's three judges – consisting of Chief Justice Yong Pung How, Judges of Appeal Thean Lip Ping (L P Thean) and M Karthigesu – took into consideration Lim's refusal of medical treatment, lack of familial support and the great danger he posed to society given his paedophilic condition, they decided to not reduce his 40-year sentence.
Extracted from Lim Hock Hin Kelvin v Public Prosecutor [1997]:
The three judges also made a benchmark ruling, which decreed that in whichever future cases, if a chronic paedophile was unable to or see no initiative to refrain himself from his sexual advances towards children, such offenders should be sentenced to the maximum penalty of life imprisonment. This legal benchmark, however, did not retroactively apply to Lim's case since he was sentenced before the date of his appeal's ruling.
In August 1998, Allan Tan Kei Loon, an 18-year-old gang member who killed a rival gang member Png Hock Seng during a street gang attack, was found guilty of culpable homicide not amounting to murder by the High Court, and the trial judge Tay Yong Kwang sentenced Tan to seven years' imprisonment and nine strokes of the cane despite the prosecution's arguments for life imprisonment and 24 strokes of the cane. By this point of time, due to Abdul Nasir Amer Hamsah's landmark appeal the year before, the definition of life imprisonment has been changed to mean the term of incarceration for the remainder of a prisoner's natural life. The prosecution appealed for a life term in October 1998, arguing that life imprisonment should be the benchmark sentence for killings that arose from gang-related fights in the interest of public order and safety, and cannot be lower than the maximum sentence for rape (which is 20 years). Under the law back then, an offence of culpable homicide not amounting to murder warranted either a life sentence, or up to ten years' imprisonment, in addition to caning or a fine.
However, the Court of Appeal disagreed with the prosecution that life imprisonment should be the benchmark sentence for gang killings, as the cases of such homicides may not arise from the same reason. Furthermore, the appellate judges stated that with the changes to the law and significant change of the length of life imprisonment from "20 years" to "natural life", they felt that this signalled the courts' need to be cautious before committing an offender, especially a young person, to life behind bars:
Extracted from Public Prosecutor v Tan Kei Loon Allan [1998] 3 SLR(R) 679:
The late High Court judge Lai Kew Chai (deceased since 2006), who delivered the verdict he finalized with Thean Lip Ping (L. P. Thean) and M. Karthigesu, also highlighted the limits to sentencing an offender to either life or up to ten years, given that judges cannot impose sentences of more than ten years but less than life, which would leave judges with the dilemma that a life term may be an excessive punishment for an offender convicted of culpable homicide, which was exactly the case for Tan based on the mitigating and aggravating factors of his case. In his own words, Justice Lai quoted:
Extracted from Public Prosecutor v Tan Kei Loon Allan [1998] 3 SLR(R) 679:
As such, the prosecution's appeal was rejected, but the Court of Appeal increased Tan's sentence to the alternate maximum term of ten years' imprisonment and 15 strokes of the cane, as they conceded in agreement with the prosecution that Tan's seven-year sentence and nine-stroke caning were not manifestly adequate to address his culpability of the killing. However, the ruling in Tan's case was frequently referred to in subsequent cases of culpable homicide before the courts, where the prosecution sought a life term for the offender(s), in which some offenders were sentenced to life in prison while others get not more than ten years' imprisonment.
Eventually, in 2008, the Penal Code was revised and Section 304 of the Penal Code was amended to allow judges to impose sentences of either life or up to 20 years in jail with/without caning and/or a fine for future cases of culpable homicide not amounting to murder from 2008 onwards.
On 14 January 2015, the prosecution appealed against the re-sentencing of Kho Jabing, a Malaysian who was convicted of the 2008 murder of a Chinese construction worker during an armed robbery. Kho was sentenced to death in 2010 for murder, but the 2013 legal reforms to the death penalty allowed Kho, like other death row prisoners in Singapore, to appeal for re-sentencing, and High Court judge Tay Yong Kwang (who is current Judge of Appeal since 2016) re-sentenced Kho to life in prison and 24 strokes of the cane. The ruling of the appeal, by a 3–2 decision, led to Kho being sentenced to death once again and he was eventually hanged on 20 May 2016 after several failed attempts to overturn his sentence.
The verdict is considered as a benchmark of sentencing guidelines for judges to decide between the death penalty and life sentence for murder, as the five judges, despite conflicting decisions between the majority and minority on the final sentence, unanimously agreed that the death penalty should be imposed in serious cases of murder where an offender, despite not having an intention to kill, exhibited viciousness and/or a blatant disregard for human life, and furthermore, if an offender's actions outraged the feelings of the community. This verdict of Kho's case effectively impacted on the outcomes of several future cases, where some murderers were sentenced to life imprisonment due to their conduct not sufficiently calling for the death sentence while others were executed.
In Singapore, both the High Court and Court of Appeal have the power to sentence an offender to life imprisonment; and the Court of Appeal could either raise a fixed sentence to life, reduce a death sentence to life or reduce a life sentence to a fixed jail term. In the cases of Ridzuan Mega Abdul Rahman and Azlin Arujunah in 2022, who were both charged for the fatal abuse of their five-year-old son, the Court of Appeal increased the couple's sentences to life imprisonment, after finding Ridzuan guilty of causing grievous harm and Azlin guilty of murder. Convicted drug trafficker Aishamudin Jamaludin (who only acted as a courier in his case), had his sentence of 25 years' jail and caning (15 strokes) for a lower drug offence increased to life imprisonment and 15 strokes of the cane in 2020 due to the prosecution's appeal to convict him of the original capital drug charge. In a 1998 landmark case relating to the successful partial defence of sudden and grave provocation against murder, a Malaysian named Kwan Cin Cheng had his sentence increased from ten years to life imprisonment for culpable homicide by the Court of Appeal, due to the judges feeling that the manner of Kwan killing his girlfriend being too deplorable and violent that a ten-year term was manifestly inadequate despite their disagreement to the prosecution's arguments for the murder charge and death penalty. In another case, the Court of Appeal allowed the appeal of 55-year-old brothel owner Chan Lie Sian, who was convicted of the murder of William Tiah Hung Wai, and they re-sentenced Chan to life imprisonment after overturning his death sentence in July 2019.
Not only that, the President of Singapore have the power to grant a death row inmate clemency and commute his or her death sentence to life imprisonment, but since 1965, there were only six successful cases of clemency (two for drug trafficking and four for murder) when the President pardoned an inmate from execution in Singapore. The last case was in April 1998 when then President Ong Teng Cheong granted clemency to 19-year-old convicted murderer Mathavakannan Kalimuthu and commuted his sentence to life imprisonment. Not only that, the President also had the power to pardon a prisoner from serving a life sentence and order the convict's release, which was the case for Sim Ah Cheoh, a drug trafficker and mother of two who suffered from terminal cancer and thus asked the President for clemency a second time to allow her to be released and spend her remaining time with her family. Sim was originally sentenced to hang in 1988 for smuggling 1.37 kg of heroin before her death sentence was commuted to life imprisonment by a presidential pardon. After then President Ong Teng Cheong approved her second clemency petition, Sim was released in February 1995, and died one month later.
However, the Court of Appeal, being the highest court of the nation, also had the authority to increase a life sentence (or any other jail term) to the death penalty, as demonstrated by several cases like Rozman Jusoh (from seven years to death), Gerardine Andrew (from eight years to death), Kho Jabing (from life to death) and Chia Kee Chen (from life to death). The courts of Singapore also had the authority to acquit a person of an offence punishable by a life term, as demonstrated by some cases like that of Ramadass Punnusamy, a 41-year-old Malaysian and alleged drug courier who was originally sentenced to life with caning (15 strokes) for smuggling 1.875 kg of cannabis by the High Court before the Court of Appeal reviewed the case and found that both Ramadass and his co-accused Raj Kumar Aiyachami (originally sentenced to death) were innocent of the alleged drug offence, leading to the acquittal and release of both Ramadass and Raj in May 2022.
Before 20 August 1997, a life sentence meant a prison term of twenty years, and like all other fixed term sentences, it carried the usual one-third remission for good behaviour, which allowed prisoners to gain parole after serving at least two-thirds of their sentences. In the case of Bobby Chung Hua Watt, a murder convict and carpenter whose death sentence was commuted to life imprisonment in January 1980 after receiving clemency, he served two-thirds of his life term (equivalent to 13 years and four months) before he was released on parole for good behaviour and had the final third of the sentence remitted.
After the landmark appeal of Abdul Nasir Amer Hamsah on 20 August 1997, although life imprisonment is meant to last for the remainder of a convict's natural lifespan, the sentence still carries a possibility of release on parole after a minimum period of 20 years behind bars. A life convict can be eligible for parole based on his conduct in prison, albeit with conditions like no further instances of reoffending while the parole order remains in force and this remission order, which suspends the prisoner's life sentence, would last until the convict's death. Even if a convict is not eligible after reaching the 20-year mark of his sentence, he will still be periodically assessed annually until the authorities are satisfied that he becomes eligible for parole. However, according to Josephus Tan, a criminal lawyer who formerly defended several criminals at risk of facing the gallows, he stated that there was "no guarantee of release" for the life term prisoners despite their right to parole and he personally did not see any post-1997 cases of a life sentence prisoner being released on parole.
One instance of a "natural life sentence" convict being released on parole was Singaporean Vincent Lee Chuan Leong, who masterminded the kidnapping of a 14-year-old girl on 9 September 1999, and within the same month, Lee and his two accomplices were arrested and they were all sentenced to life imprisonment in April 2000. According to a YouTube video, Vincent Lee, who was 33 years old when committing the crime, was currently released on parole from prison at the age of 54 since 22 June 2020 after serving a total of 20 years, ten months and nine days in prison with good behaviour, and is employed as a lorry driver. However, Lee's case was the only known and reported case of a life term prisoner released on parole.
Unlike the United States and certain Western countries like England, the current life imprisonment laws in Singapore did not adopt a practice of life without parole, and the courts in Singapore had never imposed any consecutive natural life sentences on convicts in any case since after 1997. They decreed that all those people who received fixed prison terms other than life imprisonment would have to serve their fixed jail terms concurrently with life imprisonment, unless their life sentences were reduced and thus made the fixed jail terms to run consecutively with the reduced sentence.
Similarly, an offender sentenced to two or more terms of life imprisonment would have to serve the life terms concurrently instead of consecutively. One example was Soh Wee Kian, a former National Serviceman who killed a woman and grievously stabbed three more females in four stabbing incidents. Soh, who was assessed to be suffering from an adjustment disorder and thus had his murder charge reduced, was sentenced in August 2013 to serve two life sentences – one for culpable homicide not amounting to murder and another for a charge of causing grievous hurt with dangerous weapons – by the High Court, though however, the trial court ordered Soh to serve both terms of life imprisonment concurrently instead of consecutively. A much earlier case occurred in 1984 when Beh Meng Chai, a Malaysian and one of the three perpetrators of an armed-robbery and double murder case, was sentenced to two life sentences for two manslaughter charges, as well as ten years for each charge of armed robbery, although his life terms and other sentences were ordered to be served concurrently, in addition to 24 strokes of the cane.
Under the Penal Code, there are more than forty offences that can result in life imprisonment. For certain offences, life imprisonment is the maximum penalty, while for some capital offences, life imprisonment is the minimum penalty under the law, notably murder with no intention to kill since 2013:
There is also a section of the Penal Code which slated that whoever was found guilty of committing attempted murder while serving a life sentence in Singapore, he/she would be automatically sentenced to death. Originally, the offence of rape was punishable by life imprisonment as the maximum sentence before the maximum sentence was amended to twenty years' imprisonment instead, due to the effects of life imprisonment being extended to natural life.
Under the Kidnapping Act, several kidnapping offences, notably kidnapping for ransom, dictates life imprisonment as the minimum punishment upon conviction.
Section 3 of the Kidnapping Act provides:
In certain cases of life imprisonment for kidnapping, caning is also potentially imposed (exclusively for male convicts) under certain circumstances like the vulnerability of the victim, the presence of weapons or if any harm/threat was made during the kidnapping. In the 2014 case of Sheng Siong kidnapper Lee Sze Yong, the High Court sentenced him to life imprisonment with three strokes of the cane for, with the abetment of Heng Chen Boon (who served three years' jail for wrongful confinement), abducting the 79-year-old mother of the Sheng Siong supermarket chain owner. In another kidnapping case that took place in 2003's Christmas Day, Tan Ping Koon and Chua Ser Lien (who committed suicide at Changi Prison in July 2020) were both jailed for life and caned three strokes for targeting and abducting a seven-year-old girl into their car. Selvaraju Satippan, who held a reporter and her maid hostage in 2003 and even used a knife to threaten and harm the victims, was given 24 strokes of the cane in addition to his life sentence for having committed arson, using a knife and caused harm to the hostages. Abdul Nasir Amer Hamsah, in another case, received 12 strokes of the cane and life imprisonment for kidnapping and holding two police officers hostage with another man in 1996.
In contrast to the above cases, caning was not imposed for Vincent Lee Chuan Leong and his two accomplices Shi Song Jing and Zhou Jian Guang, who were all sentenced to life imprisonment without caning for abducting a 14-year-old female student on account of their lack of criminal records and their proper care and treatment towards the girl while she was in their captivity. In the 2001 Tay Teng Joo kidnapping case, both Agnes Ng Lei Eng and Ng Soon Teck were jailed for life but spared the cane due to Agnes Ng being a female and both were unarmed unlike the mastermind Chng Teo Heng, who was caned six times (in addition to a life sentence) for using a knife.
Since 2013, the changes to the death penalty laws for capital drug trafficking allowed judges to have the discretion to sentence drug traffickers to life imprisonment, provided that they acted as couriers, cooperated with the authorities to disrupt drug-related activities and/or suffering from mental illnesses. Notable cases of traffickers who received life imprisonment includes Yong Vui Kong, a Malaysian who was initially sentenced to death before the reduction of his sentence to life.
There were also certain offences where trafficking of drugs with amounts below the capital threshold may also attract life imprisonment as a possible punishment, which is also the maximum for the trafficking of such amounts.
Under the Arms Offences Act, there were several offences that would warrant life imprisonment upon conviction, either as the mandatory sentence in some cases, or the minimum or maximum punishment for several others. These include trafficking of arms, and unlawful possessions of firearms upon arrest for any scheduled offence.
One example of a person sentenced to life in prison under the Act was Muhammad Iskandar Sa'at, a 23-year-old Singaporean who was the culprit of the Khoo Teck Puat Hospital shooting incident in 2015, in which he snatched a revolver with attempt to cause hurt to Staff Sergeant Muhammad Sadli bin Razali while attempting to escape from the hospital, where he was receiving medical treatment shortly after his capture for theft. Iskandar was sentenced to a mandatory term of life imprisonment and 18 strokes of the cane after pleading guilty to a reduced charge of unlawful possession of a firearm for causing hurt to a public servant.
Another case was Nyu Kok Meng, a Malaysian who, together with serial killer Sek Kim Wah, robbed a businessman and his family while armed with a knife and a stolen military rifle. Although Nyu did not help Sek to murder three of the five hostages, he faced charges of using a firearm to commit armed robbery under the Arms Offences Act, and he was sentenced to life imprisonment with six strokes of the cane on 9 July 1985.
Under Section 124 of the Hijacking of Aircraft and Protection of Aircraft and International Airports Act, an offender can be sentenced to life imprisonment as the mandatory punishment if they were found guilty under this Act for whichever offences related to:
This law was first enacted since 1978.
There are several conditions and exceptions for courts in Singapore to consider in cases where a person faces a potential life sentence under the law for whichever scheduled offence charged.
For instance, should a person suffering from a mental illness was charged with any offence punishable by life (or less than life), notably culpable homicide not amounting to murder (or manslaughter), the courts has to ascertain the extent of diminished responsibility suffered by the person. While the defence of diminished responsibility could enable the reduction of a murder charge to culpable homicide, it was also a condition where the judges can refer to as a relevant factor of consideration on whether life imprisonment, as the maximum punishment, should be imposed on the offender. In several cases of life imprisonment for mentally ill offenders, the judges were of the opinion that the offender should be committed to a sentence of life behind bars if the condition presents him/her as a psychiatric danger to society and to himself.
In the 2006 precedent case of 37-year-old Constance Chee Cheong Hin, a former air stewardess who abducted four-year-old Sindee Neo and threw her off the girl's flat, causing Neo to die from fatal head injuries five days later, she was sentenced to 13 years' imprisonment for wrongful abduction and culpable homicide (three years for the first charge and ten years for the second charge). In rejecting the prosecution's arguments and psychiatric opinion for life imprisonment in Chee's case, then High Court judge V. K. Rajah stated that Chee should not be liable for life imprisonment on account that she had strong familial support, with her three sisters writing to the court their affirmation to take care of Chee and ensure she had proper treatment for her schizophrenia, with one of her sisters making plans for Chee to live with her permanently after her release, and with reference to another medical report, Justice Rajah noted that with consistent and sufficient medical treatment, Chee's schizophrenic condition would eventually get better and hence, her psychiatric condition was not severe enough to the extent of needing to have Chee separated from society for as long as life, thus making life imprisonment inappropriate for her.
The case of Constance Chee was referred to in several cases. One of the cases was Guen Garlejo Aguilar, a Filipino maid who killed her friend Jane Parangan La Puebla and disposed of two suitcases containing the victim's dismembered body parts at Orchard Road and MacRitchie Reservoir respectively. Aguilar, who was found to be suffering from depression, pleaded guilty to a reduced charge of culpable homicide and sentenced to ten years in jail. V. K. Rajah, the judge who also heard Constance Chee's case, heard Aguilar's case and took into consideration the root of her illness being her financial woes, and that with strong familial support, and her progressive recovery from depression since the start of her treatment while in remand, Aguilar's future risk of re-offending was low. Justice Rajah quoted about the conduct of Aguilar under influence of her depression, "By choosing to plant the deceased's head and torso in two very public places, her behaviour strikes one as nothing short of incoherent and incomprehensible,... Her post-offence conduct was baffling and testament to the workings of a tortured mind".
Another was the 2005 case of 27-year-old Lim Ah Liang, a male prostitute who stabbed and hammered his 37-year-old lover Ho Kien Leong to death. Lim was initially charged with murder but pled guilty to culpable homicide due to dysthymia, a life-long depressive disorder, that severely impaired his mental faculties at the time of the killing. The trial judge, V. K. Rajah (judge of the above two cases), having considered the elderly age of Lim's mother and stepfather, the lack of familial support, and the lifelong need to subject Lim to medication and a controlled environment based on his condition, decided to sentence Lim to life imprisonment.
Since 2013, the changes to the Misuse of Drugs Act decreed that all judges were to impose a mandatory life sentence for drug traffickers who were suffering from mental illnesses, provided that their conditions had substantially impaired their mental responsibility at the time of the offence. This requirement for eligibility, if fulfilled, could spare such drug offenders from the death penalty in spite of the amount of drugs exceeding the capital threshold.
In the case of Dinesh Pillai Reja Retnam, he became the first drug trafficker to have his death sentence lowered to life imprisonment during a 2013 re-sentencing trial by the High Court on the grounds of diminished responsibility, as he was assessed to suffer from depression at the time he trafficked 19.35g of heroin. Pang Siew Fum, the 60-year-old accomplice of drug courier Cheong Chun Yin (who smuggled 2,726g of heroin from Myanmar to Singapore), was also re-sentenced to life imprisonment in 2015 as a result of depression. Upon his appeal in 2022, 50-year-old Roszaidi Osman's death sentence was reduced to life imprisonment by the Court of Appeal through a 3–2 majority decision on account of his depression and substance use disorder despite his offence of trafficking 32.54g of pure heroin.
However, for cases of people who were mentally unsound when they commit any offences that warrant life imprisonment, they would be acquitted of any charges and indefinitely detained at the President's Pleasure, and they would serve their detention at a mental facility, prison or any other safe places in custody. These offenders would be subject to regular psychiatric assessments until they were found mentally fit and suitable for release back into society. In September 2022, Commonwealth double killer Gabriel Lien Goh was acquitted of culpable homicide not amounting to murder (punishable by life) for killing his mother and grandmother in October 2019, as he was found to be suffering from acute hallucinogen intoxication at the time of the killings and hence was of substantial unsound mind when he committed the murders of his mother and grandmother, since his drug consumption caused him to experience illusions, hallucinations and paranoid delusions at the time of the offences. After this acquittal, Goh was detained at the President's Pleasure.
There was no minimum age set for a person to be sentenced to life imprisonment. However, certain laws still prohibit the imprisonment of children, although with a few exceptions.
Under Section 37 of the Children and Young Persons Act (CYPA), it was decreed that a child below the age of 14 years will not be incarcerated for any offence. This is similarly applied for a person aged 14 and above but below 16, who would be detained at a juvenile rehabilitation centre, although the courts had the authority to order otherwise through evaluations of his character. These two above laws prohibit life imprisonment for young offenders from these two age groups.
However, if a child or young person is convicted of a very serious crime that potentially requires a sentence of life imprisonment, and the court found that life imprisonment was the only available and suitable option to deploy during sentencing, the offender will be detained for a period of time as specified in the sentence under Section 38 of the CYPA. They would be subjected to similar conditions for eligibility of parole like adult offenders serving life in prison.
Under Section 314 of the Criminal Procedure Code from 2010 onwards, if a person was found guilty of committing murder, drug trafficking or other offences punishable by death when he was below 18 years old, the convict would not receive the death penalty, and instead, he would be committed to a mandatory term of life imprisonment as an alternative punishment instead. Before its abolition in 2010, a sentence of indefinite detention at the President's Pleasure was imposed for minors who commit capital crimes while under the age of 18.
The first underaged offender to be sentenced to life imprisonment for a capital offence was Zin Mar Nwe, a Myanmar maid who was charged with killing an elderly Indian woman at Choa Chu Kang in June 2018. Zin Mar Nwe, who used a knife to stab the 70-year-old victim 26 times (and it led to the woman's death), was 17 years old when she committed the offence, and after the defendant was found guilty of murder in May 2023, the trial judge Andre Maniam noted that Zin was a minor at the time of the offence, and the Criminal Procedure Code also prohibited the imposition of capital punishment for offenders who were below 18 when committing murder, and that a life sentence should be the only punishment required for such cases. As a result, Zin Mar Nwe was spared the gallows and instead, she was sentenced to life imprisonment on 4 July 2023.
There was also no legislation that prohibit the imposition of life imprisonment for elderly offenders who commit crimes that warrant such a sentence in Singapore. However, in several cases, where an elderly offender faces a sentence of either life or less than life for any crimes punishable by life, the courts and/or lawyers (from either the prosecution or defence) would be cautioned against imposing imprisonment terms that may exceed the remainder of the defendant's lifespan, meaning that the sentence should not be contextually as long as life imprisonment in view of the defendant's age or health, unless in any exceptional circumstances. In the case of Tan Nam Seng, a 72-year-old retired shipping company owner who was convicted of culpable homicide for killing his 38-year-old son-in-law Spencer Tuppani in 2017 for cheating on his daughter (also Tuppani's wife) and business, the judge Dedar Singh Gill noted that Tan suffered from major depressive disorder, as well as two heart attacks and tuberculosis while in remand, and thus exercised his leniency to sentence Tan to eight-and-a-half years' jail on 21 September 2020 due to his advanced age and increasingly poor health. In another case, 86-year-old Pak Kian Huat, alias Pek Kiah Huat, who was charged in 2019 for using a chopper to hack his 79-year-old partner Lim Soi Moy to death over her refusal to let him use a bigger bedroom, was sentenced to 15 years' jail for culpable homicide, with the trial judge See Kee Oon calling the offence "deliberately and unspeakably vicious and brutal" for Pak's remorseless conduct and his actions of inflicting 54 knife wounds on Lim over a trivial dispute, and stated that Pak's advanced age was not a mitigating factor in light of the brutality of the attack and would have warranted life imprisonment, which the prosecution did not pursue.
However, in cases where an elderly offender was found guilty of a criminal offence that mandates a life sentence, or a capital charge that attracts a sentence of either life or death, the courts were not restricted from the possibility of sentencing such convicts to life imprisonment if they felt that the death penalty is inappropriate or that the life sentence was the only option. In the case of 69-year-old Seet Cher Hng, who was convicted of murder for killing his wife Low Hwee Geok at ITE College Central in 2018, the High Court sentenced him to a life term after the prosecution decided to not pursue the death penalty. Similarly, for 67-year-old Toh Sia Guan, a homeless man who fatally stabbed 52-year-old coffee shop helper Goh Eng Thiam during a fight at Geylang in 2016, he was found guilty of murder and sentenced to life in prison in 2020, despite his advanced age and poor health. In a third case, Pung Ah Kiang, a Singaporean who was 61 years old at the time of sentencing, was sentenced to life imprisonment as he was acting as a mere courier when he assisted 41-year-old Malaysian Kishor Kumar Raguan (sentenced to death) to traffic 36.05g of heroin.
This section covers the list of defendants, mainly Japanese army and Kempeitai officers, who were responsible for the war atrocities that occurred during the Japanese occupation of Singapore (1942–1945), and they were tried and sentenced to life terms in Singapore under British laws enacted by the colonial government: