1 The accused, Joseph Lim Dia Lek (“Mr Lim”), currently a 19-year-old Singaporean, committed a spate of shop thefts on ten occasions from September 2024 to 19 May 2026 when he was between 17 and 18. The total value of the stolen items amounted to $556.10. The items were either recovered or almost full restitution (shy of S$45) were made in respect of them.

2 Mr Lim pleaded guilty to three charges of shop theft under section 380 of the Penal Code 1871 (2020 Rev Ed), one of which amalgamated two occasions when taken together amounted to a course of conduct under section 124(4) of the Criminal Procedure Code 2010 (2020 Rev Ed) (“CPC”). He also consented to have five other similar charges taken into consideration for the purpose of sentence (“TIC”).

3 On 25 May 2026, I convicted Mr Lim and called for both probation and reformative training (“RT”) pre-sentence reports (“PSRs”) on him. While his PSRs were prepared, a ninth charge in respect of the latter shop offence committed on 19 May 2026 was tendered against Mr Lim on 17 July 2026. At the mention on 28 July 2026, the prosecution offered and he consented to have the charge TIC. His probation officer sought an adjournment whilst awaiting receipt of Mr Lim’s previous psychiatric report to prepare his PSR. I also directed the Singapore Prison Service (“SPS”) to review its RT PSR submitted on 29 June 2026 ¹ in the light of the new TIC charge.

4 Mr Lim’s probation officer subsequently returned an assessment of non-suitability for probation. ² The SPS maintained its assessment on him of physical and mental suitability for the RT regime at Level 2 intensity of rehabilitation. At the mention on 27 August 2026, the prosecution indicated its sentencing position for Mr Lim to be placed on RT. I adjourned mitigation and sentencing for SPS to confirm Mr Lim’s mental suitability for RT (because it was indicated in the PSR that previous clinical notes were pending and the PSR made no mention of Mr Lim’s psychiatric report) and to clarify the basis for recommending RT at Level 2 intensity of rehabilitation, or otherwise consider the feasibility of RT at Level 1 intensity instead. This was also to afford time for Mr Lim to consider legal representation, which Mr Lim’s parent declined to do on his behalf. I also intimated that I wished to explore alternative sentencing options with the prosecution. Subsequently, the SPS submitted a revised PSR confirming Mr Lim’s mental suitability for RT and maintaining its earlier recommendation for him to undergo RT at Level 2 intensity of rehabilitation. ³

5 At the last mention on 23 September 2026, the prosecution maintained its sentencing position for Mr Lim to be placed on RT. During oral mitigation, Mr Lim, who is self-represented, sought a rehabilitative sentence to complete his national service (“NS”). Since he starting serving NS, he learnt skills and to manage stress, made new friends, took his medication regularly and did not commit any further offences. He opined that completing NS would be more helpful in changing him as compared to intensive RT, which would stress him more.

6 Having reserved my judgment on sentence and after much consideration, I agree with the informed assessments in the PSRs and the prosecution’s position that I should order Mr Lim to undergo RT at Level 2 intensity of rehabilitation, which carries a minimum period of 12 months’ incarceration. I do not do this lightly. The overarching goal is still very much to rehabilitate Mr Lim and if we were to have any reasonable shot at success without the efforts in this regard ending up in futility, rehabilitation has to be done in a structured environment because Mr Lim is clearly incapable of being left to his own devices to achieve this with minimal intervention. The court does not make an order in vain. I explain the reasons for my decision.

7 I previously delivered brief reasons on 25 May 2026 explaining why I called for both probation and RT PSRs on Mr Lim. I outline these reasons for context.

8 I should generally call for a probation PSR before sentencing a young offender who is aged 21 or below: A Karthik v PP [2018] 5 SLR 1289 at [20] and [21]. In Mr Lim’s case, the basic prerequisites for probation are met. His theft offences are not offences for which the sentences are fixed by law: section 5(1) of the Probation of Offenders Act 1951 (2020 Rev Ed) (“POA”). For the unamalgamated theft charges, Mr Lim faces mandatory imprisonment for a term which may extend to seven years that can be coupled with a fine. He faces double the maximum prescribed punishment for the amalgamated charge by virtue of section 124(8)(a)(ii) CPC. The sentences are therefore fixed in type but not in quantum; the court must impose imprisonment with or without a fine, but has the discretion to decide on the length of imprisonment and the quantum of the fine: Mohamad Fairuuz bin Saleh v PP [2015] 1 SLR 1145 at [17(c)]. The proviso to section 5(1) of the POA also does not apply as the offences are not punishable with either a specified minimum sentence or mandatory minimum sentence. Mr Lim also does not have any previous convictions.

9 Furthermore, I did not think that probation was unviable or unrealistic for Mr Lim, and the court should order a probation PSR if the accused is young (ie, between 16 and 21 years old), a first offender and convicted of a relatively less serious crime: Wong Shan Shan v PP [2008] SGHC 49 at [20]-[21]. Mr Lim is a young offender between 17 and 18 at the time of the offences. He is 19 at the time of sentencing today. He is also a first-time offender. ⁴ As for the severity of his offences, the offenders in A Karthik and Wong Shan Shan were arguably convicted of more serious charges or more charges: Cheah Bernice [2024] SGDC 220 at [14]. In both cases, the appellate court thought that probation PSRs ought to have been called on the offenders.

10 Where rehabilitation is the dominant sentencing consideration, probation would be one of the typical options at the court’s disposal, given that probation places rehabilitation at the front and centre of the court’s deliberation: A Karthik at [67].

11 There was, however, also a need to inject some element of deterrence, both general and specific, into the overarching focus of rehabilitation in Mr Lim’s case.

12 Mr Lim committed the theft offences in 2024, 2025 and 2026. In response to shop-theft being one of the top crimes of concern in 2024 that accounted for 21.2% of total physical crime cases with a 7.6% increase in cases as compared to 2023, I observed in PP v Praveen Nivash Velmurugan [2025] SGDC 45 at [21] that general deterrent sentencing should be pressed into service to increase the cost of crime to send a categorical message to like-minded offenders that it does not pay to shoplift. Although there was a subsequent decrease of 3% in the number of cases in 2025 as compared to 2024, I opined that the principle of general deterrence should continue to be pressed into service for such offences so as not to undo this modest improvement and to prevent a reversal of this encouraging but nascent trend: PP v Tham Quan Hui [2026] SGDC 79 at [21]. As it subsequently turned out, the number of shop theft cases has increased by 2.2% in the first half of 2026 as compared to the same period in 2025, and accounted for about 20.4% of the total number of physical crime cases. ⁵

13 The multiplicity of Mr Lim’s offences also troubles me. I set out the chronology of his offences which puts the quantitative nature of his recidivism into proper perspective:

Qualitatively, although he has been diagnosed with attention deficit hyperactivity disorder (“ADHD”), conduct disorder (“CD”) and unspecified anxiety disorder, he was assessed, when remanded for forensic psychiatric evaluation, not to have been psychologically distressed prior to the offence; he did not have depression or psychosis at the time of the offence and his anxiety disorder did not contribute to the offence. ⁶ Indeed, the fact that he re-offended on 19 May 2026, barely four months after he was charged in court and released on court bail, was telling of the true nature of his recalcitrant behaviour.

14 Mr Lim was also wholly culpable given his deliberate conduct of pilfering:

(a) in respect of the amalgamated charge, he entered an unmanned convenience store on two occasions by squeezing through the exit turnstile instead of using his bank card to open the turnstile to enter the store, stole 17 food and beverage items and left the store without paying for them, whilst being captured on surveillance footage; ⁷ and

(b) as for his shop theft at the bookstore, he stole the 19 items by taking them off the display shelves and hiding them in his bag before leaving the store without paying for them, triggering the store’s anti-theft alarm system and was detained. ⁸ He deployed the same mode of operation for his shop theft at the toy store by removing 11 keychains from the display shelves and placing them in his bag, but was caught by store staff. ⁹

15 There is therefore a consequent need to consider RT as a possible sentencing option to incorporate a sufficient element of deterrence within the overarching focus on the goal of rehabilitation with a minimum incarceration period of six or 12 months that is not a feature of probation: PP v Koh Wen Jie Boaz [2016] 1 SLR 334 at [34] and [39]. Where there is a need for both deterrence and rehabilitation, RT may be the most suitable sentence, given that it offers a useful middle ground between sending the offender to prison and meeting the desire to rehabilitate a young offender: A Karthik at [67]. I was therefore not closed to RT as a possible rehabilitative-deterrent/punitive sentencing option. The offences and Mr Lim’s offending behaviour stand at the cusp of the intersection between rehabilitative and deterrent concerns. I ordered for him to be remanded at the reformative training centre for a week for an RT PSR to be prepared and submitted to the court. He continued to be on bail thereafter from 29 May 2006 after the remand period.

16 When sentencing a young offender, the first stage is to identify and prioritise the primary sentencing considerations appropriate to the offender having regard to all the circumstances including those of the offence. The second stage is to select the appropriate sentence that would best meet those identified and prioritised sentencing considerations: PP v Mohammad Al-Ansari bin Basri [2008] 1 SLR(R) 449 at [77]-[78] and PP v Koh Wen Jie Boaz [2016] 1 SLR 334 (“Boaz Koh”) at [28] as affirmed and explained in PP v ASR [2019] 1 SLR 941 at [94], [101]-[102]. The inquiry proceeds from the foremost question of whether rehabilitation remains the dominant sentencing principle.

17 At the first stage, the question is whether in all the circumstances, the presumptive emphasis on rehabilitation has been displaced: See Li Quan Mendel v PP [2020] 2 SLR 630 (“Mendel See”) at [15]. If an offender is 21 years old or below at both the time of the offence and the time of sentencing, the law takes the presumptive view that the primary sentencing consideration in such cases will generally be rehabilitation, because both the retrospective and prospective rationales underlying such presumptive primacy of rehabilitation would apply: A Karthik v PP [2018] 5 SLR 1289 at [44].

18 In this case, Mr Lim was between 17 and 18 at the time of the offences, He is 19 at the time of sentencing today. The primacy of rehabilitation is therefore presumptive. But the focus on rehabilitation can be diminished or even eclipsed by such considerations as deterrence or retribution where the circumstances warrant, where:

19 With its prevalence and significant costs, shop theft offences should not be dismissed as mere petty economic crime. In Mr Lim’s case, one of the theft charges is also aggravated, doubling an already harsh maximum prescribed punishment because of its amalgamated nature. The harm caused by Mr Lim’s offences is decidedly low, but only fortuitously because the stolen items for the majority of the offences were recovered. I have already analysed Mr Lim’s recalcitrance, which was not brought about by his psychiatric conditions: see [13] and [14], above. More importantly, the conditions do not exist to make probation viable as evinced by Mr Lim’s probation PSR.

20 I cannot say that the presumptive primacy of rehabilitation has been entirely or significantly displaced such that it plays second fiddle to other sentencing considerations, but there are real and legitimate deterrent and retributive concerns that need to be adequately addressed within any rehabilitative focus.

21 Having determined that Mr Lim should still be rehabilitated, I next have to ascertain how this ought to be achieved and his suitability to undergo a specific form of rehabilitation: ASR at [99]. The second stage is to select the appropriate sentence that would best meet this emphasis on rehabilitation while having sufficient deterrent ‘bite’. Indeed, the opinion and recommendation in his forensic psychiatric evaluation was that he would “benefit from having proportionate consequences to act as a deterrent for future offending”. ¹⁰

22 Where rehabilitation is the dominant sentencing consideration, probation would be one of the typical sentencing options that the court can consider. In this case, the conditions do not exist to make probation such a viable or realistic option as is evident from Mr Lim’s probation PSR. The opinion of the probation officer is not and should not be conclusive on the issue of sentencing, nor does it bind the court to a certain decision: Praveen s/o Krishnan v PP [2018] 3 SLR 1300 at [65]. However, I am slow to depart from the recommendations of Mr Lim’s probation officer in her trademark comprehensive report because there is nothing to suggest that there was no proper basis for them, or that they were based on circumstances that were factually incorrect or have since materially changed: A Karthik at [79].

23 Mr Lim’s probation officer did not recommend probation for him. Her recommendation was properly founded on the Level of Service/Case Management Inventory (“LS/CMI”) that is “a reliable and validated structured instrument designed to assess the risk of re-offending and rehabilitation needs of offenders aged 19 and above”. ¹¹ It was also premised on sufficiently broad-based sources of information. ¹²

24 Mr Lim’s risk of re-offending was assessed to be high as compared to other male offenders on probation orders when the risk and protective factors were balanced. ¹³

25 I agree with Mr Lim’s probation officer that he was not a suitable probationer because the risk factors outweigh the protective factors:

(a) his entrenched anti-social attitude and lack of insight into his present offences. He reportedly started stealing in 2018 at home, ¹⁴ first shoplifted in 2022, ¹⁵ shoplifted from his campus supermarket on five occasions in July 2024, ¹⁶ was issued a 12-month conditional warning for theft in-dwelling and placed on Guidance Programme in 2025, during which he re-offended twice, ¹⁷ culminating in the present set of offences, to which he pleaded guilty and consented to have them TIC, but from which he subsequently dissociated himself during interviews with his probation officer; ¹⁸

(b) multiple breaches of trial time restriction. He did not respond to his probation officer’s video call curfew check on 10 June 2026, ¹⁹ and broke his curfew on 25 July 2026, 2 and 8 August 2026 despite a reminder not to do so on 28 July 2026; ²⁰

(c) ineffectual parenting. Mr Lim was somewhat responsive to his father; ²¹ he was unresponsive to his mother, who was his main caregiver and disciplinarian and who has disengaged from him. ²² Mr Lim’s parents were unaware of his whereabouts, activities and friends as he did not wish to be contacted by them. ²³ This was even so during the period of his trial time restriction; ²⁴ as well as

(d) the need for continued psychiatric and psychological interventions because of his ADHD and CD conditions. Since 2016, Mr Lim was prescribed medication and received individual behavioural therapy to address his ADHD. ²⁵ His ADHD was unremediated when he refused medication and his parents were also unsure if he was taking his medication. ²⁶ While previously remanded for forensic psychiatric evaluation, he was assessed to be:

Despite his probation officer’s instructions to take his medication in the presence of his parents on 10 and 30 June 2026, he did not do so as he did not wish to wait for his father to wake up in the morning to supervise him. ²⁸ His father also admitted to not doing so as he would be asleep when Mr Lim took his medication, and this state of affairs persisted despite a reminder on 30 June 2026. ²⁹

26 Mr Lim wished to be placed on probation but was unwilling to reside in a hostel “as he did not wish to lose his freedom” and “would like to retain his freedom” and “did not wish to be monitored 24/7”. ³⁰ He also affirmed that he “would ensure he paid for items he wanted instead of resorting to stealing”. ³¹ His track record says otherwise that he is likely to abuse his freedom and reoffend if left to his own devices, given his latest transgression on 16 May 2026 while on bail. He “[e]xpressed confidence in abiding by the probation conditions, as he opined that he had been abiding by the trial conditions thus far”. ³² That cannot be further from the truth when he had breached the trial time restriction on multiple occasions and this only showed his lack of insight into his non-compliant and defiant behaviour. I am equally less optimistic about his “willingness to attend community service, programmes and to continue his psychiatric and psychological interventions and medication”. ³³ He has failed to abide by his probation officer’s direct and repeated instructions to take his medication in his parents’ presence, and it therefore could not be verified whether he has been keeping up with his medication regime, which is a linchpin of his successful rehabilitation. Worryingly, there also appears to be a festering of persistent inappropriate personal sexual behaviour at home ³⁴ and during NS ³⁵ that needs to be nipped in the bud before Mr Lim’s pilfering behaviour escalates to sexual misconduct against others.

27 Although Mr Lim’s parents have expressed willingness to make probation work for Mr Lim, including attending parenting programmes, working closely with the probation officer to monitor and supervise Mr Lim, monitor his curfew abidance and any new purchases, I am, with respect, less confident of their ability to do so given their limited success in the past attributable to “parenting inconsistencies”, “long-standing lack of [providing to Mr Lim] appropriate adult guidance”, “limited parental capacity” and the nature of the subsisting parent-child relationship. ³⁶ This is quite evident from Mr Lim’s multiple breaches of his trial time restriction, their continued lack of awareness of his whereabouts and their inability to supervise his medication regime. To be sure, this is not an indictment of their parenting but it is clear that they require dire assistance in this regard and more than minimal intervention is needed.

28 The SPS found Mr Lim suitable to undergo the RT regime.

29 Mr Lim was physically and mentally assessed to be suitable for RT, ³⁷ and recommended to undergo the regime at Level 2 intensity of rehabilitation to be delivered over the course of 12 months on the basis that Mr Lim would:

30 An RT PSR does not contain a positive recommendation for an offender to undergo RT, and understandably so because the law does not confer any mandate for the prison authorities to make any such recommendation as to whether an offender ought to be sentenced to RT as opposed to other forms of punishment. Such a report is meant to reflect whether an offender is physically and mentally fit, and in that sense suitable, for RT: Ng Jun Xian at [54]. Even though Mr Lim has been found suitable for RT by SPS, I must apply my mind to whether he should be sentenced to RT as such.

31 The rehabilitation plan of the RT PSR is premised on adequate sources of information. ³⁹ Mr Lim presented multiple criminogenic needs ⁴⁰ that requires more intensive intervention of psychology-based correctional programmes (developed on evidence-informed theories, methodologies that are relevant for the youth population, and adheres to the principles of effective rehabilitation), in addition to the programmes provided at Level 1 intensity, to be delivered over a 12-month period. ⁴¹

32 First, he has displayed the same dissociative attitude towards his crime ⁴² and more time is required to effect a mindset change through a better appreciation of his offences and offending conduct so as to rid him of his pilfering habit.

33 Second, Mr Lim displayed limited responsiveness to interactions with the SPS’ correctional rehabilitation specialist ⁴³ and also had limited social interactions, ⁴⁴ which programmes targeted at character development to strengthen his personal efficacy and interpersonal skills will need to work on. He also had difficulties in educational engagement and achievement ⁴⁵ and vocational training could be helpful in this regard.

34 Third, as Mr Lim would benefit from the continued support of his family, family integration programmes to strengthen family bonds and establish a supportive family network would be useful, especially in the face of Mr Lim’s strained relationship with his mother, as well as inconsistent parenting approaches. ⁴⁶

35 Fourth, the structured environment of NS, specifically the largely stay-in nine-week period of his basic military training, appears to have done some good for Mr Lim in instilling some discipline in him, ⁴⁷ and is a good precursor to his response to an RT regime. This is particularly important for his medication regime, especially when Mr Lim is not eligible for a mandatory treatment order (“MTO”) because of the enhanced punishment prescribed by his amalgamated theft charge: section 337(2)(c) CPC. Mr Lim would benefit from the longer 12-month RT period that would get him into the rhythm of regular medication that will likely engender a greater measure of success with self-medication requiring minimal supervision upon release when he acclimates and reintegrates into the NS environment with the resumption of his NS obligations. Although Mr Lim has no history of alcohol or illicit drug use, ⁴⁸ he lacks structured and constructive leisure/recreational activities. ⁴⁹ It is also noteworthy that despite the regimental nature of NS, he has been caught during with infractions of personal sexually inappropriate behaviour that has carried over from his behaviour at home in this regard. Psychology-based interventions over a sustained period during RT, rather than ill-equipped one-off warnings and reactive disciplinary actions, will be more effective in nipping this festering behaviour in the bud.

36 In order to assess whether Mr Lim should undergo RT to reform him and to prevent crime, I need to have regard to his character, previous conduct and the circumstances of the offences: section 305(1) of the CPC. Considerations of proportionality have been imported into the “circumstances of the offences” limb of this provision: PP v Saiful Rizam bin Assim [2014] 2 SLR 495 (“Saiful Rizam”) at [38]. Had I been minded to impose a sentence of imprisonment on Mr Lim, it would be nowhere close to the minimum 12-month period of incarceration for an RT sentence at Level 2 intensity of rehabilitation. But a sentence of imprisonment does not make for easy and direct comparison with that of RT because it is fundamentally a very different and more severe punitive sentence, whereas RT is still rehabilitative in nature with a deterrent element. Mr Lim is also not eligible for a short detention order (“SDO”) because of the maximum prescribed punishment for his theft-in-dwelling offences, even if unamalgamated: section 337(1)(i) CPC.

37 Even if the minimum detention periods might not be proportionate to the underlying offence, the principle of proportionality legitimately takes a back seat with a view to reforming the young offender and deterring him at an early stage: Sim Yeow Kee v PP [2016] 5 SLR 936 at [95]. However, as much as the rehabilitative effect of RT is a valuable and important sentencing goal, a measure of proportionality in making orders for RT is also imperative so that offenders are not unduly punished: Saiful Rizam at [41]. In a related vein, I am cognisant of the observations in Mohamed Erzan Taib Zohri v PP [2026] SGHC 183 at [60] that:

38 Because of the nature of the charges that have been preferred against Mr Lim, other rehabilitative options, such as a community sentence comprising an SDO, community service order and an MTO, which I would have preferred to consider to impose, is not open to Mr Lim. Although I would also have imposed a much shorter term of imprisonment if I did not impose a sentence of RT, it is clear to me that exposing Mr Lim to the potentially unsettling influence of an adult prison environment far outweighs the perceived fairness of a shorter incarceration term.

39 There is also a need for a more robust interventionist approach in Mr Lim’s case. First, his recalcitrance, which features both past and present recidivism, is symptomatic of a deeply-rooted mindset driven by his ADHD and CD conditions. This requires sustained psychiatric and psychological interventions in a structured environment because he is clearly incapable of being left to his own devices and robust supervision against the backdrop of a nurturing environment is lacking at home. Second, he had also previously refused the monitoring of his medication regime and there was no sure way of verifying whether he has kept up with it. When taking medication, he was better in his behaviour but when his behavioural problems escalated, he often refused medication, with regular therapy with him and his family yielding limited benefit. ⁵⁰ Third, he is also selectively responsive even though his intelligence quotient is in the normal range and he is not intellectually challenged. ⁵¹ Fourth, he poses a high risk of offending and therefore a concomitant danger to the prevention of crime in the meanwhile. Fifth, there is a risk that his pilfering behaviour may escalate to sexual misconduct against others if his personal sexually inappropriate behaviour were not corrected in time.

40 It is therefore clear to me that Mr Lim has his work cut out for him. Much work needs to be done during his sentence of RT to rehabilitate and deter him to prevent crime, when previous interventions had failed him. I reiterate that the court does not make an order in vain. I should not order a sentence of RT at Level 1 intensity of rehabilitation to pay lip service to proportionality if the six-month period over which to deliver the necessary interventions is insufficient to afford a reasonable measure of success to rehabilitate and deter Mr Lim.

41 I therefore sentence Mr Lim to RT for a minimum detention period of 12 months from today. This is to reform him and prevent crime given the specific rehabilitation plan that has been drawn up for him. It is not only a viable and feasible but the appropriate sentence to impose on him.