1 This is the application of the Law Society of Singapore (the “Law Society”), seeking an order that Willjude Vimalraj s/o Raymond Suras (the “respondent”), an Advocate and Solicitor, be struck off the Roll of Advocates and Solicitors of the Supreme Court of Singapore (the “Roll”). The Law Society has made this application under ss 94A(1) and 98(1) of the Legal Profession Act 1966 (2020 Rev Ed) (the “LPA”) as the respondent has been convicted of offences involving fraud or dishonesty.

2 Having considered the submissions of the parties, we agree with the Law Society that the respondent should be struck off the Roll, for the reasons that follow.

3 The respondent was admitted as an Advocate and Solicitor of the Supreme Court of Singapore on 10 February 2021.

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

5 The respondent was an Investigating Officer (“IO”) in the Singapore Police Force (“SPF”) when he forged witness statements he had been required to record in the course of his investigations into various criminal matters. The offences took place between 30 November 2018 and 21 January 2019, which was before the date of his admission as an Advocate and Solicitor of the Supreme Court. The respondent crafted statements based on notes from phone interviews with witnesses, backdated the statements, and appended false signatures to the statements. He also added fictitious accounts without reading them back to the witnesses, and in some cases at least, he crafted statements from scratch without even contacting the witnesses.

6 The false evidence charge pertained to the respondent’s making of a false statement in his affidavit for admission to the Bar (the “admission affidavit”). After resigning from the SPF on 19 April 2019, he applied to be admitted as an Advocate and Solicitor. At the material time, he knew he was subject to ongoing investigations by the SPF Internal Affairs Office (“IAO”) for acts of forgery. He had been served a Notice of Investigation on 21 February 2019 which informed him that the IAO had commenced investigations for an offence of forgery under s 465 of the Penal Code, and he had signed and acknowledged the notice on 26 February 2019. Despite this knowledge, he declared in his admission affidavit dated 22 December 2020 that he was not “the subject of any pending investigation or proceedings in Singapore or elsewhere in respect of any criminal offence”, when he was legally bound to state the truth.

7 The respondent also consented to 29 other charges for forgery punishable under s 465 of the Penal Code being taken into consideration for the purpose of sentencing. These 29 charges pertained to the respondent’s forgery of witness statements recorded for the purposes of criminal and coroner’s cases.

8 The respondent was sentenced to an aggregate term of 25 months’ imprisonment with effect from 18 July 2024.

9 The Attorney-General’s Chambers (“AGC”) notified the Law Society of the respondent’s conviction by a letter dated 3 September 2024. The AGC requested the Law Society “to take the necessary action under [s] 94A(1) of the [LPA]” because the respondent had been “convicted of offences involving fraud or dishonesty”. Section 94A(1) of the LPA states that the Law Society must, without further direction, proceed to make an application under s 98 of the LPA when a regulated legal practitioner has been convicted of an offence involving fraud or dishonesty.

10 On 24 April 2025, the Law Society filed the present application seeking an order pursuant to s 98(1) of the LPA, that the respondent be dealt with in such manner as provided for in s 83(1) of the LPA. The Law Society has stated in its submissions that it seeks an order that the respondent be struck off the Roll under s 83(1)(a) of the LPA read with ss 83(2)(a) and 83(2)(h) of the LPA.

11 Section 83(2)(a) of the LPA states that “due cause may be shown by proof that an advocate and solicitor has been convicted of a criminal offence, implying a defect of character which makes him or her unfit for his or her profession”. For the purposes of this application, the respondent’s conviction must be accepted as final and conclusive: s 83(6) of the LPA.

12 We are amply satisfied that due cause has been shown for the respondent to be struck off the Roll.

13 Misconduct involving dishonesty will almost invariably lead to an order for striking off where the dishonesty reveals a character defect rendering the errant solicitor unsuitable to be a member of the profession or that threatens to undermine the administration of justice. This would typically be the case where the dishonesty in question is integral to the commission of the criminal offence of which the solicitor has been convicted. Striking off will be the presumptive sanction, unless there are “truly exceptional facts” showing that a striking off would be disproportionate, which will be “extremely rare”: Law Society of Singapore v Chia Choon Yang [2018] 5 SLR 1068 (“Chia Choon Yang”) at [39].

14 In the present case, the dishonesty is clearly integral to the commission of the respondent’s offences. In relation to the forgery charges, the respondent pleaded guilty to and was convicted of making false documents “with the intention to commit fraud”. It cannot be gainsaid that forgery is dishonesty: see Law Society of Singapore v Jaya Anil Kumar [2019] SGHC 12 at [4]. Furthermore, this court has held that an act of false attestation necessarily involves dishonesty given that the person has asserted a fact or state of affairs that he knew to be untrue: Chia Choon Yang at [15]. Similarly, in relation to the false evidence charge, the respondent pleaded guilty to and was convicted of “intentionally giv[ing] false evidence in a judicial proceeding”. The respondent asserted in his admission affidavit that he was not subject to any criminal investigations in Singapore although he knew this to be untrue (see above at [6]). There is no doubt therefore that the dishonesty is integral to the commission of the respondent’s offences.

15 We did consider the fact that the offences in question preceded the respondent’s admission as an Advocate and Solicitor. In line with this, the Law Society did also include an alternative prayer in their written submissions for the respondent to be struck off under s 16(4) of the LPA. Section 16(4) states that the name of an Advocate and Solicitor “must be struck off” the Roll if it is shown to the satisfaction of the court, at any time after their admission, that any affidavit filed by them “contains any substantially false statement or a suppression of any material fact”. We observe that s 16(4) could apply in this case because the respondent’s admission affidavit contains a substantially false statement: Attorney-General v Shahira Banu d/o Khaja Moinudeen [2024] 4 SLR 1324 (“Shahira Banu”) at [22]. The falseness of the statement was substantial and crossed the de minimis threshold of materiality: Attorney-General v Phua Jill [2024] SGHC 214 (“Jill Phua”) at [10], for the following reasons. The respondent knew that his statement in his admission affidavit was false (see above at [6]) and the fact that he was subject to criminal investigations would undoubtedly have affected his admission to the Bar: see, for example, Re Mohamad Shafee Khamis [2024] 6 SLR 173.

16 The date of the commission of the respondent’s offences is however irrelevant for the purposes of striking off under s 83(2)(a) of the LPA. All that is required for s 83(2)(a) to apply is proof that an Advocate and Solicitor has been convicted of a criminal offence. In other words, the relevant temporal marker for s 83(2)(a) is the solicitor’s date of conviction, which should invariably be after the solicitor’s admission to the Bar. Where the conviction occurred before the admission to the Bar, it will have been considered by the court considering the application for admission; and where for some reason the court has been kept in the dark as to the conviction, then it may be dealt with under s 16(4).

17 Likewise, there is nothing in the plain language of ss 94A(1) and 98(1) to suggest that those provisions could not apply in a case such as the present. Pertinently, s 94A(1) similarly states that the provision applies where a “regulated legal practitioner has been convicted of an offence involving fraud or dishonesty” [emphasis added].

18 Therefore, although s 16(4) of the LPA could also have applied in the present case, we did not think it was either necessary or appropriate to strike off the respondent under that provision. It would not be necessary to do so because the Law Society has correctly made this application under ss 94A(1) and 98(1) and we are amply satisfied that due cause has been shown for the respondent to be struck off the Roll under s 83(2)(a). Further, it would not be appropriate to apply s 16(4) here because that provision is typically, though not necessarily, directed at situations where the primary focus remains on rehabilitation: see Shahira Banu and Jill Phua. By contrast, the respondent’s conviction took place after his admission to the Bar, and its nature is such that it reveals a serious character defect that brings the need for the protection of the public to the fore.

19 We also agree with the Law Society that there are no exceptional circumstances at all that would suggest that a striking off order would be disproportionate or otherwise inappropriate. The circumstances cited by the respondent both at the hearing and in his written submissions are not mitigating. For example, there is no evidence to suggest that the respondent’s diagnosis of Major Depressive Disorder caused him to make a false statement in his admission affidavit. Moreover, the fact that the respondent may not have received any “monetary gain” from committing the offences is wholly irrelevant given the serious harm caused to the administration of justice. As the Law Society emphasises in its written submissions, the respondent was entrusted with significant public power in order to discharge his responsibilities as an IO, and when he forged witness statements, he demonstrated a fundamental breach of that trust. Furthermore, as the Law Society highlights, the respondent, by making the false statement in his admission affidavit, did fraudulently secure admission to the Bar.

20 In any event, where the presumptive sanction of striking off applies, matters concerning personal culpability, and for that matter, personal mitigating factors generally, have little relevance: Chia Choon Yang at [39]. Mitigating factors are not treated in the same way in disciplinary proceedings as they are in criminal proceedings, because the principal purpose of disciplinary sanctions in the professional setting is to protect the public and uphold confidence in the integrity of the legal profession: Chia Choon Yang at [17].

21 Therefore, due cause has been shown for the respondent to be struck off the Roll, and we so order.

22 We fix the costs of this application in favour of the Law Society in the sum claimed by the Law Society which we consider to be reasonable, and that is $6,000 for costs and disbursements in the amount of $1,110.75.