Public Prosecutor v Gumede Sthembiso Joel [2023] SGDC 268 Case Number __ District Arrest Case No 902134-2023, Magistrate's Appeals Nos MA-9194-2023-01 Decision Date —_* 06 November 2023 Tribunal/Court + District Court Coram Eddy Tham Counsel Name(s) ‘ Eric Hu and Lee Da Zhuan (Attorney-General's Chambers) for the Public Prosecutor; Defence Counsel Ms Stephania Wong Wan Kee (M/s Rajah & Tann LLP) for the Accused Parties Public Prosecutor — Gumede Sthembiso Joel Criminal Law ~ Offence ~ 51(1)(a) Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 - Trial - Statutory Interpretation [LawNet Editorial Note: An appeal to this decision has been filed In MA 9194/2023/01.] 6 November 2023, District Judge Eddy Tham: INTRODUCTION 1 The Accused faced a total of three charges, namely two charges under section 5(1) of the Endangered Species (Import and Export) Act 2006 (“ESA”) and one charge under section of the 51(1)(a) Corruption, Drug ‘Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 ("CDSA") 2 The Accused initially intended to plead guilty to all the three charges. Subsequently, after the Court had questioned on the validity of the CDSA charge and invited parties to make submissions on the CDSA charge, the Accused decided to claim trial to this charge. 3 The trial for the CDSA charge proceeded before me, As all the material facts were agreed upon, the trial proceeded with the Prosecution’s case resting fully on a statement of agreed facts ("Statement of Agreed Facts”) 4 At the end of the Prosecution’s case, I found that the charge has not been made out and I accordingly acquitted the Accused. 5 The Prosecution being dissatisfied with the acquittal has filed an appeal against it 6 now set out the grounds of my decision in respect of the acquittal‘THE CHARGE 7 Iset out here the CDSA charge in full you, on 4 October 2022, In Singapore, were concerned in an arrangement, knowing that by the arrangement the contro! by Jaycee Israel Marvatona (“Jaycee”) of his benefits from criminal conduct, namely, 20 pieces of rhinoceros’ horns concealed in two bags weighing a total of approximately 34.7 kg, which were the benefits of an offence against the law of the South African National Environmental Management: Biodiversity Act 10 of 2004, s 57(1), which, if the conduct had occurred in Singapore, would have constituted a serious offence under s. 4 of the Endangered Species (Import and Export) Act 2006, would be facilitated by transporting the said horns from South Africa to Laos through Singapore, and knowing that Jaycee Is @ person who engages in criminal conduct, and you have thereby committed an offence under s 51(1)(a), punishable under s 51(5)(a) of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992. ‘THE PROSECUTION’S CASE The Statement of Agreed Facts Agreed facts in relation to the arrest of the Accused and the offences under section 5 of the ESA 8 The Accused is Gumede Sthembiso Joel, a 33-year-old male South African national 9 On 4 October 2022 at about 9 a.m., at Changi Airport Terminal | , an officer in charge of screening X-ray images of transit luggage noticed two cardboard boxes, wrapped in plastic cling wrap, containing several organic items shaped like horns (the "Boxes") 10 The Boxes bore baggage tags with the Accused's name, Investigations showed that the Accused had checked in the Boxes on 3 October 2022 at the O. R. Tambo International Airport in Johannesburg, South Africa (CORT Airport"), bound for Changi Airport onboard flight SQ479. The Accused was thus the person in charge of the Boxes from the point of check-in at Johannesburg and fell within the definition of "owner" under the ESA 11 The Accused was on board flight $Q479 and landed in Singapore on 4 October 2022 at about 7 a.m. He intended to take a connecting flight from Singapore to Vientiane, Laos via flight TR350 later at 9.15 a.m. the same day. 12 Following the detention of the Boxes, the Accused was informed via a public announcement to report to the Changi Airport Police Command. He was escorted to an inspection room at Changi Airport. In the inspection room, both Boxes were opened in the Accused's presence. A total of 20 pieces of rhinoceros’ horns, weighing approximately 34.7kg in total, were discovered to be concealed in two travel bags, one red and one grey, each Packed in one of the two Boxes. 13 The Accused was arrested on the same day (4 October 2022) and the two travel bags packed in the cardboard boxes containing 20 pieces of horns, each wrapped in cling wrap, weighing a total of approximately 34.7kg (the "Horns") were seized from him under section 11(1)(c) of the ESA. 14 DNA analysis by NParks' experts confirmed that all 20 Horns are genuine rhinoceros’ horns, comprising: 1 18 pieces weighing 2 total of approximately 31.987kg from white rhinoceros (Ceratotherium simum); andii, Two pieces weighing a total of approximately 2.713kg from black rhinoceros (Diceros bicornis). 15 Ceratotherium simum and diceros bicornis are species from the Rhinocerotidae family, listed in the Schedule to the ESA. The ESA gives effect to the Convention on International Trade in Endangered Species of Wild Fauna and Flora ("CITES"). Both species are listed in Appendix I of the CITES. 16 Samples of the Horns were sent to the Faculty of Veterinary Science, University of Pretoria, COnderstepoort Campus, South Africa (the "Faculty") for expert DNA analysis. The intent of the analysis was to determine whether the DNA from the Horns matched the DNA profiles from case samples in the rhinoceros DNA database maintained by the Faculty's Veterinary Genetics Laboratory. The Faculty's expert confirmed that the 18 pieces came from 15 different southern white rhinoceroses, and the two pieces came from one black rhinoceros. Additionally, 15 samples were traced to 11 female rhinoceroses, and the reproduction of such species could have been halted as a result of possible illegal poaching activities. 17 Based on a report published in 2020 by the United Nations Office on Drugs and Crime ("UNODC") titled "World Wildlife Crime Report” (Exhibit ABI), the estimated wholesale value of rhinoceros’ horns from 2014-2018 was USD 24,300 per kg. On that basis, the Horns would have an estimated wholesale value of USD 843,210, Which is equivalent to approximately SGD 1,200,140,79 as of 4 October 2022. Separately, based on a report produced by the Wildlife Justice Commission, a non-profit foundation, in 2022 titled "Rhino horn trafficking as a form of transnational organised crime” (Exhibit AB2), the average value of rhinoceros’ horns (limited to within South Africa) is USD 7,529 per kg. On this basis, the Horns would have an estimated export value of USD 261,256.30, which is equivalent to approximately SGD 371,846 as of 4 October 2022. 18 The Accused did not possess any valid CITES export or re-export permit issued by a competent authority in South Africa in relation to the Horns. 19 The Accused, had thus, on 4 October 2022, sometime between about 7 a.m. and 9.15 a.m., at Changi Airport Terminal 1 Arrival Hall, being the owner of 18 pieces of white rhinoceros’ horns (Ceratotherium simum) totalling 31.987kg, and two pieces of black rhinoceros’ horns (Diceros bicornis) totalling 2.713kg,which at the material time was in transit in Singapore on the way to Vientiane, Laos, did bring the Horns from Johannesburg, South Africa, into Singapore without a valid CITES export or reexport permit issued by a competent authority in South Africa, of the scheduled species (these facts would constitute offences under section 5(1)(a) read with section 5(4) of the ESA which the Accused intends to plead guilty to) Agreed facts in relation to the CDSA charge 20 The Accused was acquainted with one Jaycee Israel! Marvatona ("Jaycee"), a male South African national. ‘The Accused had known Jaycee for two or three years after a mutual friend introduced them. Since July 2022, the Accused knew that Jaycee was involved in the illegal rhinoceros horn trade. Jaycee would send images and videos of rhinoceros’ horns to the Accused, 21 The duo discussed looking for persons "to travel" for trips arranged by Jaycee. The Accused also discussed with Jaycee on possible options to hide rhinoceros’ related cargo on 27 August 2022. 22 Sometime in or before September 2022, Jaycee requested the Accused to transport rhinoceros’ horns from South Africa to Laos, through Singapore. In return, Jaycee informed the Accused that he would make his, trip “worthwhile and provide return tickets and cash. The Accused agreed. He provided Jaycee with his Passport details to facilitate the flight booking and application for the Laos eVisa. Jaycee also asked the ‘Accused to look for someone who could travel with him to Laos in October 2022. 23 On the morning of 3 October 2022 at 7.33 a.m., the Accused sent Jaycee a photograph of the attire he would be wearing for the flight to Singapore. At 10.30 a.m., the Accused met Jaycee at the Mugg and Bean restaurant at ORT Airport. Jaycee had with him a trolley with the Boxes on it. Jaycee directed the Accused totake the Boxes to a specific check-in counter A25, while Jaycee observed from a distance. At counter A25, the Boxes were weighed but not checked in. Jaycee and the Accused then reunited at the Byte Café and Restaurant at ORT Airport. 24 After some time, Jaycee instructed the Accused to return to counter A25 again, with the Boxes, Jaycee reminded the Accused to act normal and not bring any attention to himself. The Accused complied. At counter A25, the Boxes were weighed and processed for check-in by the ORT Airport staff. After checking in the Boxes, the Accused boarded flight SQ479 to Singapore at 1.55 p.m. 25 Prior to the Accused boarding his flight, Jaycee requested that the Accused provide him his bank account details. The Accused sent him a screenshot of the details of his company's account, Fontec (PTY) Ltd., with the First National Bank ("Fontec's account"). At around 1.29 p.m. on 3 October 2023, a sum of ZAR 9,000 (approximately SGD 670) was deposited into Fontec's account, Jaycee also reminded the Accused to keep in contact throughout the journey to Laos, and the Accused agreed. Jaycee sent the Accused a soft copy of a Laos. eVisa approval letter at 5.42 p.m. 26 Colonel Johan Jooste ("Colonel Jooste"), National Commander with the Wildlife Trafficking Serious Organised Crime of the Directorate for Priority Crime Investigation of the South African Police Service of the Government of South Africa, provided a statement under section 74 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 ("CDSA") (Exhibit AB3) on behalf of the Government of South Africa, stating that South African investigations revealed that Jaycee had bought rhinoceros’ horns (including the present Horns) from poachers in South Africa and sold them to a person known as ‘Jimmy’ Jaycee also assisted Jimmy to illegally transport rhinoceros’ horns without a valid permit to other countries. For this purpose, Jaycee recruited couriers such as the Accused. 27 The Horns found in Singapore had been exported out of South Africa illegally, without a required permit, which constitutes an offence under section 57(1) of the African National Environmental Management: Biodiversity Act 10 of 2004 ("NEMBA"). 28 — South African Police found baggage tags, corresponding to the two Boxes in the Accused’s possession in Singapore, at Jaycee's residence in South Africa. According to Colonel Jooste's statement under section 74 of the CDSA, Jaycee informed the South African Police that the Accused was actively involved In recruiting more couriers to export rhinoceros’ horns. 29. Jaycee's conduct, i.e., the sale of the Horns to ‘Jimmy’ and the syndicated export of the Horns from South Africa to Laos without CITES permits in connection with such sale, if it had occurred in Singapore, would have constituted offences under section 4 of the ESA, which are "foreign serious offences” under section 2 read with the Second Schedule of the CDSA. THE ELEMENTS OF THE OFFENCE AND THE ISSUES TO BE DETERMINED The Elements of the Offence 30 The relevant provision of the CDSA charge read as follows: 51(1) Subject to the subsection (3), a person who enters into or is otherwise concerned in an arrangement, knowing or having reasonable grounds to believe that, by the arrangement —the retention or control by or on behalf of another (called in this section that other person) of that other person's, benefits from criminal conduct is facilitated (whether by concealment, removal from jurisdiction, transfer to nominees or otherwise)and knowing or having reasonable grounds to believe that that other person is a person who engages in or has engaged in criminal conduct or has benefited from criminal conduct shall be guilty of an offence. 31 Reading the charge together with the statutory provision, the elements of the offence which would have to be proved by the Prosecution would be as follows: (a) The Accused was concerned in an arrangement; (e) knowing that by the arrangement the control by Jaycee of his benefits from criminal conduct, namely, the Horns; (©) which were the benefits of an offence against the law of the South African National Environmental Management: Biodiversity Act 10 of 2004, s 57(1), which, if the conduct had occurred in Singapore, would have constituted a serious offence under s. 4 of the ESA; (4) would be facilitated by transporting the said horns from South Africa to Laos through Singapore; and (2) knowing that Jaycee is a person who engages in criminal conduct. 32 Based on the Statement of Agreed Facts, the Accused knew that Jaycee was involved in the illegal rhinoceros horn trade, The Accused had also knowingly agreed to help Jaycee to transport rhinoceros’ horns from South Africa to Laos, through Singapore, in return for free air ticket and cash. 33 °Criminal conduct” has been defined under section 2 of CDSA as “doing or being concerned in, whether in Singapore or elsewhere, any act constituting a serious offence or a foreign serious offence". 34 A “foreign serious offence” has also been defined under the same section as “an offence (other than a foreign drug dealing offence) against the law of a foreign country or part thereof that consists of or includes conduct which, if the conduct had occurred in Singapore, would have constituted a serious offence". 35 A “serious offence” has been further defined under the same section as including any of the offences specified in the Second Schedule of the CDSA. The Second Schedule has listed section 4 of the ESA as such an offence, 36 It Is not disputed that the act of Jaycee’s act of sale of the Horns to Jimmy and exporting the Horns out of South Africa without the necessary permit would, if it had occurred in Singapore, have constituted an offence under section 4 of the ESA. Accordingly, the offences would qualify as “foreign serious offences" under section 2 read with the Second Schedule of the CDSA, 37 Its therefore common ground that all the elements of the offence have been proved by the facts as set out in the Statement of Agreed Facts save for the element of whether the Horns could constitute the “benefits” of Jaycee’s criminal conduct. The crux of this trial turned on the interpretation of the phrase “of that other person's benefits from criminal conduct” in section 51(1)(a) of the CDSA, The Law of Statutory Interpretation 38 The purposive approach to statutory interpretation has been laid out clearly by the Court of Appeal in Tan Cheng Bock v AG [2017] 2 SLR 850 ("Tan Cheng Bock") 39. The 3-step purposive approach is as follows:(2) First, the court is to ascertain the possible interpretations of the provision, having regard not just to the text of the provision but also to the context of that provision within the written law as 2 whole, (b) Second, the court is to ascertain the legislative purpose or object of the specific provision and that should ordinarily be gleaned from the text itself before the court evaluates whether extraneous material Is necessary. Extraneous material may only be used to ascertain the meaning of the provision where the provision is ambiguous or obscure on its face, or where the ordinary meaning of the provision leads to a result that is manifestly absurd or unreasonable, (©) Third, the court Is to compare the possible interpretations of the text against the purposes or objects of the statute and to prefer the interpretation which furthers those purposes or objects over that does not. 40 Twill now set out my analysis of the evidence to determine this issue, ANALYSIS OF THE EVIDENCE What is the ordinary meaning of the phrase “the other person’s benefits from criminal conduct”? The first step of the purposive approach 41 In applying the first step of ascertaining the possible interpretations of the provision, the court should do so by determining the ordinary meaning of the words and this task can be aided by several rules and canons of statutory construction, all of which are grounded in logic and common sense (see [38] of Tan Cheng Bok). 42 I had asked Prosecution what the ordinary meaning of the phrase “benefits from” would be and Prosecution had responded that based on the ordinary meaning from the Oxford English Dictionary, it would mean an “advantage, profit, or gain”inete: 1) 43 Lagree. When read with the connecting words “from criminal conduct”, I found that the ordinary meaning conveyed by the phrase “the other person’s benefits from criminal conduct” would be the “advantage, profits or gains" resulting from the criminal conduct. In other words, these benefits were benefits received by Jaycee as a result of or in consequence of the criminal conduct he had engaged in. 44 I therefore found myself in agreement with three propositions put forth by the Defence in their submissions: (a) First, the benefit must be something extraneous that is gained, acquired or obtained by the Primary offender and cannot originate from the primary offender, (b) Second, the benefit must be gained, obtained or acquired after the criminal conduct has been carried out, and not before. (©) Third, the benefit must be gained, obtained and/or acquired by the primary offender as a result of the criminal conduct. 45 _ 1 found these propositions logical and consistent with the ordinary meaning of the phrase, The second step of the purposive approach46 1 also found that this interpretation is in line with the legislative purpose of the provision within the context of that provision as well as of the statute. This Is applying the second step of the purposive approach. ‘The sub-heading for section 51 of the CDSA reads “Assisting another to retain benefits from criminal conduct”. The provision Is quite clearly targeted at preventing a criminal from enjoying the fruits of his crime, through preventing such benefits from being moved or controlled with the help of another person. 47 This purpose is also evident from subsection 4 of section $1. When setting out a possible defence to an offence under section 51, it is provided that an accused can prove that he did not know and had no reasonable ground to believe that the arrangement related to “any person’s proceeds derived from criminal conduct’. ‘This highlighted phrase reinforces the interpretation that the subject matter being targeted are proceeds which were obtained from the criminal act 48 Such a similar theme is seen elsewhere in the CDSA as noted by the Defence, namely, section 7 of the CDSA with the title “Confiscation orders for benefits derived from criminal conduct”; and section 11 of the CDSA, with the title "Assessing benefits derived from criminal conduct”. 49 The legislative intent of the CDSA has also been expressed by the Court of Appeal in Yap Chen Hsiang Osborn v Public Prosecutor [2019] 2 SLR 31913 (at [40]), where it was stated that "the purposes of the CDSA are to deprive criminals of the ability to enjoy the fruit of their criminal conduct ...”. (my emphasis) 50 The Defence has in their submissions, further bolstered their interpretation of the legislative intent with reference to extraneous materials such as the history of the CDSA gleaned from two precursor legislation : the Corruption (Confiscation of Benefits) Act (Cap 65A, 1990 Rev Ed) ("CCBA"); and the Drug Trafficking (Confiscation of Benefits) Act (Cap 84A, 1993 Rev Ed) ("DTA"), and the Parliamentary readings for DTA in 1999. ‘The materials showed that same legislative purpose. 51 It was also highlighted that in Ang Jeanette v Public Prosecutor [2011] SGHC 1006 ("Ang Jeanette”), the High Court had discussed the statutory background of the CDSA and observed that one of the key objectives behind the enactment of the CDSA was to align Singapore's domestic legislation with the requirements of the United Nations Convention against Ilicit Traffic in Narcotic Drugs and Psychotropic Substances, 1988 (the “Vienna Convention”) and the United Nations Convention against Transnational Organised Crime and the Protocols thereto (the "Palermo Convention"). 52 It is noted that Article 6 of the Palermo Convention states: "Criminalization of the laundering of proceeds of crime” which provides that each State Party shall adopt, in accordance with fundamental principles of its domestic law, such legislative and other measures as may be necessary to establish as criminal offences, when committed intentionally the conversion or transfer of property, knowing that such property is the proceeds of crime, for the purpose of concealing or disguising the illicit origin of the property or of helping any person who is involved in the commission of the predicate offence to evade the legal consequences of his or her action. 53. The definition of “proceeds of crime" is found in Article 2 of the Palermo Convention, which provides that it shall mean “any property derived from or obtained, directly or indirectly, through the commission of an offence’. (my emphasis) 54 The purpose of this Convention clearly ran through the various Articles. V K Rajah JA (as he then was) had stated that (at [31]) that "the purpose of the Vienna Convention and Palermo Convention was to deal with people involved in the laundering of actual proceeds of crime”. 55 _I found that all the extraneous materials and references to judgments cited by the Defence had comprehensively showed that CDSA was clearly targeted at “proceeds of crime” which had been obtained by the primary offender as a result of the commission of the predicate offence. The third step ~ other possible interpretations56 Prosecution had in their submissions identified the issue as whether the subject matter of the ESA offences (J.e., the rhinoceros’ horns) can constitute benefits from the criminal conduct for the CDSA offencelnote: 21, This identification is partially correct as ultimately this issue will have to be addressed, 57 However, the Prosecution then went on to try to argue that the subject matter of the ESA charges and the CDSA charge can be the same rhinoceros’ horns. With respect, the Prosecution had gone onto the wrong path to answer this issue. This is because before one can answer the question of whether the Horns can be the “benefits”, one will have to interpret the word “benefits” from the context in which it was used. The Prosecution did not address this at all 58 Instead, the Prosecution focused their arguments on: (a) The ESA charges and the CDSA charge penalise different acts by the Accused; (b) Benefits from criminal conduct need not be cash or money; (©) Different charges can be brought for the same incident; and (d)__ The CDSA and ESA charges aim to protect different legally protected interests 59 The issue is clearly not about whether the Horns by themselves can amount to “benefits” or whether they can form the same subject matter for both CDSA and ESA charges, Certainly, no one can argue that Horns do have intrinsic value and can amount to benefits to a person. It is also not the issue that proceeds of a crime can only be in the form of cash or money and as money can easily be converted into other forms of property. ‘The CDSA Is enacted to catch all forms of property so long as there is a link between the property to the crime, 60 At stake is the interpretation of whether the benefit must flow from the criminal conduct of a person and this the Prosecution had failed to address in their submission. 61 _In my view, an object can be both the subject of an offence and can also represent the benefit of the criminal conduct of the offender. Such an example would be the theft of a luxury bag. In this example, a person (A) stole a luxury bag and handed it over to a friend (B) and asked B to bring the bag to another place. The bag was both the subject matter in the offence of theft and would also represent the benefit of A’s criminal conduct for the purpose of a CDSA offence committed by 8. 62 The critical question is whether the object can be said to be the proceeds of a crime which had been obtained by A through committing the crime. This question can be answered in the affirmative in the above example. It would fit in the ordinary definition of a benefit from criminal conduct. Before the criminal conduct of theft was committed, A would not have any control over the bag as the bag would be in the possession of the owner. It was only as a result of the offence of theft and after it has happened, that A had the possession of the bag and was in a position to ask B to move the bag. 63 In the absence of any other possible interpretation of “benefits from criminal conduct”, I am only left with one possible interpretation at this third step of the purposive approach and that is the one which had been put forward by the Defence. I found this interpretation accorded with the ordinary meaning of the phrase “benefits from” and would be in line with the overall legislative intention of the provision as well as with the Act as a whole. Application of the interpretation to the evidence64 From the interpretation that I have accepted, two things stood out clearly. First, the logical sequence is that for that something to amount to a benefit that has been derived from criminal conduct, that something could only have come into being, subsequent to the criminal conduct. That is the element of time. 65 Second, the criminal conduct caused the benefit to be received or acquired by the person. This is the element of causation. 66 Applying this interpretation to the facts, the first thing that need to be identified is the criminal conduct of Jaycee. This would be the act of Jaycee as set out at [29] above which was taken from the Statement of Agreed Facts. Jaycee'’s criminal conduct refers to the sale of the Horns to ‘Jimmy’ and the syndicated export of the Horns from South Africa to Laos without CITES permits in connection with such sale. 67 Applying the interpretation as I have found to this evidence, the benefits of the criminal conduct could not be the Horns, Instead it would be what Jaycee had obtained from the illegal sale of the Horns, namely whatever was paid by Jimmy to Jaycee. This evidence was not included in the Statement of Agreed Facts as it was silent on what benefits were obtained by Jaycee in this transaction 68 Applying the definition of benefits from criminal conduct in respect of the 2 elements which I derived from the definition, in terms of time, the Horns already came into the control of Jaycee even before the sale to Jimmy had taken place. As set out in the Statement of Agreed Facts, Jaycee had first obtained the Horns from poachers before he sold the Horns to Jimmy. 69 Applying the test of the second element, causation, I found that the illegal sale of the Horns from Jaycee to Jimmy did not cause or lead to Jaycee acquiring or obtaining the Horns. On the contrary, the sale of the Horns resulted in Jaycee having to part possession with the Horns and consequently, the Horns were seized on transit to Jimmy. Hence, the clear conclusion is that the Horns could not be said to be benefits from Jaycee’s criminal conduct. 70 To hold that the Horns are the benefits from Jaycee’s criminal conduct of the sale and export of the same Horns would do violence to the plain language of the words in the legislation and did not accord with the legislative purpose of the CDSA. 71 Accordingly I found that whilst the Accused was concerned in an arrangement to facilitate the control of the Horns by Jaycee, such Horns did not constitute the benefits from Jaycee’s criminal conduct. The Accused’s act of transporting the Horns from South Africa without the relevant permit would instead be an offence under the ESA and should rightly be dealt with under that Act. CONCLUSION 72 At the end of the Prosecution’s case, I found that there was no evidence adduced by Prosecution to support the essential element of "benefits from criminal conduct” in the proceeded charge, I accordingly acquitted the Accused. note: LINotes of Evidence, 5 October 2023, 15/3-9. note: 2IProsecution’s Supplementary Submissions at [8(a)] BACK TO TOP Copyright © Government of Singapore.