The Court of Appeal in Lee Chez Kee (C.A.) handed down a judgment with respect to the law on common intention and hearsay in criminal cases which has already attracted two case notes. This note adds to them by focusing on a particularly thorny issue before the Court, which is the relationship between the two statutory regimes providing for the admissibility of hearsay statements: the Criminal Procedure Code and the Evidence Act, especially section 30. The case is unusual in that the Court rendered dissonant judgments with different outcomes. Choo Han Teck J. concurred with V.K. Rajah J.A.'s analysis that the confessional statements were not admissible, and thought that there was a need for a retrial, given the prejudicial nature of the evidence wrongly admitted. Rajah J.A.'s view was that there was no need for a re-trial as the other evidence was sufficient to establish the guilt of the accused.

Animal law is a little-known subject in Singapore. However, the increase in public_x000D_ awareness and concern about animal welfare issues demand that more attention is_x000D_ directed at the legal aspects of such issues. An opportunity to examine this area of_x000D_ the law arose in the case of Ling Chung Yee Roy. The District Court, presided by_x000D_ District Judge Ng Peng Hong, had to decide whether the accused was guilty of an_x000D_ animal cruelty offence under s. 42(1)(e) of the Animals and Birds Act. The section_x000D_ provides that "[a]ny person who causes, procures or, being the owner, permits to_x000D_ be confined, conveyed, lifted or carried any animal in such a manner or position as_x000D_ to subject it to unnecessary pain or suffering shall be guilty of an offence." This_x000D_ case is important for two reasons. First, it adds to the few existing local case law_x000D_ on animal cruelty. It is the first time a Singapore court has considered a situation_x000D_ that falls short of obvious cruelty. This made it necessary for the court to examine_x000D_ more carefully the legal requirements of the cruelty offence, particularly the meaning_x000D_ of "unneccesary suffering", in order to determine the scope of its application. By contrast, the previous cases all involved serious abuse, which clearly amounted to a cruelty offence, thus making it unnecessary to state the scope of the offence with precision. Secondly, the case was decided shortly after the government accepted the recommendation of the Animal welfare Legislation Review Committee ("AWLRC") to amend the ABA to impose a duty on a person responsible for an animal to ensure its welfare. An examination of the relationship between cruelty law and welfare law will be useful in determining the continued importance of Ling Chung Yee Roy when the statutory amendment comes into force.

The debate over whether the doctrine of lawful act duress exists has been settled in the affirmative by the UK Supreme Court in Times Travel (UK) Ltd v Pakistan International Airlines Corpn. However, the elements by which one establishes lawful act duress was the subject of disagreement between Lord Hodge (who delivered the majority judgment) and Lord Burrows. The disagreement stems from how illegitimate pressure should be constructed. Should illegitimate pressure be ascertained from all the circumstances—without the necessity for a more detailed analytical structure? Or given the lawful nature of the threat, should one focus on what renders the demand unjustified, and require proof of a bad faith demand and conduct which created or increased the victim’s vulnerability? We examine the debate over the existence of the doctrine, how it should be analysed, and how the answers are impacted by the existence of other legal controls over bargaining power and the value placed on the freedom of contract.

An agreement for the sale and purchase of real property often begins with an option to purchase ("OTP").2 Usually, upon agreeing on the purchase price, the vendor will grant the purchaser an OTP in return for an option fee. During the specified option period, the vendor is bound to keep the property for the purchaser. This affords the purchaser an opportunity to reconsider his or her decision to purchase the property and time to source for financing for the purchase. If the purchaser decides to proceed with the purchase, he or she will exercise the OTP by the prescribed method and within the option period, upon which the vendor is obliged to complete the transaction. In Woo Kah Wai CA, the issue before the Court of Appeal was whether the vendors were contractually obliged to grant an OTP containing terms demanded by the purchaser in the first place. To determine whether a contract to this effect has arisen, it is necessary to examine the method by which the OTP was sought to be procured. This case provides the opportunity to consider how basic principles of contract formation apply in the process of procuring an OTP, and also how subtle legal distinctions between the different methods of procuring an OTP have bearing on practical matters.