FEATURES

Singapore's 1958 Constitution: Fifty Fascinating Facts from
Fifty Years

An article commemorating the 50th anniversary of the Singapore (Constitution) Order in Council 1958.

Introduction
The first constitution to give Singapore's inhabitants a real say in their government was the Singapore Colony Order in Council 1955. Coming after three months of consultations over 37 meetings (including two in public), this Constitution - more popularly known as the Rendel Constitution (after the Constitutional Commission's chairman, Sir George Rendel) - ushered in a new era in Singapore politics. Even so, David Marshall - later to become Singapore's first chief minister - declared in late 1954 in his political manifesto, I Believe, that 'the Rendel Constitution of next year is out of date today'. Marshall was particularly perturbed by the British government's decision to retain control over the portfolios of finance, administration and internal security, and did his utmost to hurry the British along in their timetable of decolonisation and to devolve power. Even though Marshall was Chief Minister for all of 14 months, his agitation resulted in the abandonment of the Rendel Constitution and the drafting of the Singapore (Constitution) Order in Council in 1958 - exactly 50 years ago. Few people remember this anniversary, so here are 50 fascinating facts and reasons why more people should.

1 - A Constitutional Template
From 1958 to 1965, Singapore morphed from colony to self-governing state to special autonomous state in the Federation of Malaysia to an independent state. Despite these tumultuous changes, many features of the 1958 Constitution remain staples in today's Constitution. These will be highlighted below.

2 - Colony to State
From 1819 to 1866, Singapore was administered as a presidency from Fort William (modern day Calcutta or Kolkata) in India. Singapore merged with the other British territories of Penang and Malacca to become the Straits Settlements in 1867 and was administered as a Crown Colony by the Colonial Office in London. In 1946, following the end of World War II, the British government decided to disband the Straits Settlements and merge Penang and Malacca with the Federated and Unfederated Malay States to form the Malayan Union. Singapore was thus transformed into the Colony of Singapore and continued to be administered from London. With the passage of the 1958 Constitution, Singapore attained the status of a self-governing state with its own head of state and ceased to be a colony, leaving the control of foreign affairs, defence and internal security in the hands of the British.

3 - Preamble
This was the only constitution in Singapore's history to have a significant preamble. While preambles are not generally a substantive part of the Constitution, it often espouses the key philosophical values and aspirations of the people. This preamble significantly details the genesis of the 1958 Constitution through the agreements reached in London during the 1957 Constitutional Conference. Of special interest are the creation of the Internal Security Council and the first mention of minority rights and the special position of the Malays.

4 - Rights of Minorities
The question of individual rights has never been articulated in any constitutional document right up till 1958. The first serious attempt to incorporate any kind of individual rights - in this case, minority rights and the special position of the Malays - was made during the 1956 Constitutional Talks in London. In his memorandum to the colonial government, David Marshall, Singapore's first Chief Minister, appended a 'Heads of Agreement' which included a clause which contains many of the words with which we are now fairly familiar. Paragraph 8(8) of this document provides:

That it shall be the duty of the Government of Singapore at all times to protect the political, economic, social and cultural interests of the Malays, Eurasians and other minorities domiciled in Singapore. It should also be the deliberate and conscious policy of the Government of Singapore at all times to recognize the special position of the Malays, who are the indigenous people of the Island and are most in need of assistance, and within the framework of the general good of Singapore, to support, foster and promote their political, economic, social and cultural interests, and the Malay language.

These words were affirmed by the British government during the constitutional talks of 1957 and encapsulated in the Preamble of the 1958 Order-in-Council (or Constitution) almost verbatim. The only changes made were to the words 'at all times to protect the political, economic, social and cultural interests of the Malays, Eurasians and other minorities domiciled in Singapore' which was changed to 'it shall be the responsibility of the Government of Singapore constantly to care for the interests of racial and religious minorities in Singapore'.

5 - Governor to Yang di-Pertuan Negara
The British appointed Sir Harry St George Ord (1819-1885) as the first Governor to the Straits Settlements in 1867. Ord held this post till 1873 when he was succeeded by Sir Andrew Clarke. From 1867, the British Crown controlled Singapore through the Governor who wielded almost absolute power on behalf of the British monarch right up till 1958 when the Constitution was amended to create a new local head of state, the Yang di-Pertuan Negara.

6 - United Kingdom Commissioner
With the creation of a self-governing state, the British retained control over defence, foreign affairs and internal security through the presence of the Queen's representative, the United Kingdom Commissioner. The position was created under Part III of the Constitution and among other things, the Commissioner was empowered to assume control of the government in the event the Constitution was suspended. When William Allmond Codrington Goode stepped down as Yang di-Pertuan Negara, he became the first United Kingdom Commissioner. He was succeeded by George Nigel Douglas-Hamilton, the 10th Earl of Selkirk (1906-1994) who was the second and last United Kingdom Commissioner under the 1958 Constitution.

7 - Powers of the Yang di-Pertuan Negara
As the Yang di-Pertuan Negara replaced the Governor as Singapore's head of state, he was given tremendous powers under the 1958 Constitution. Among his powers were the power to dispose of land, grant pardons, appoint government officers, and submit petitions to the Queen on behalf of the people of Singapore. However, the Yang di-Pertuan Negara held his office at the Queen's pleasure and was expected to act on the instructions of the British government.

8 - Discretion of the Yang di-Pertuan Negara
Under the 1958 Constitution, the Yang di-Pertuan Negara acted as the Queen's representative and, as such, did not possess any personal discretion in the carrying out of his function. So, while his powers were more extensive than any modern-day President, he acted more as a proxy for the British government. His term of office was for four years. The post of Yang di-Pertuan Negara was abolished in 1965 after Singapore became independent and was replaced by that of the President.

9 - First Yang di-Pertuan Negara
As part of the transition to statehood, the last British Governor of Singapore, Sir William Allmond Codrington Goode (1907-1986) also became the first Yang di-Pertuan Negara of Singapore. Six months after the Constitution came into force, Goode retired from Singapore and Yusof bin Ishak (1910-1970), a Malay journalist who founded the Utusan Melayu, became Singapore's first local-born Yang di-Pertuan Negara. He retained this post when Singapore was part of the Federation of Malaysia between 1963 and 1965, and, on independence, became Singapore's first President. He died in office in 1970. During the negotiations for self-government, representatives of the United Malays Nationalist Organisation ('UMNO') in Singapore pressed for the appointment of a Malay as the first Yang di-Pertuan Negara.

10 - Appointment of Yang di-Pertuan Negara
Under the 1958 Constitution, the Yang di-Pertuan Negara was appointed by the Queen by Commission under Sign Manual and Signet (actual signature and seal) 'from among persons born in Malaya'. Before the Queen makes this appointment, the government of Singapore must be consulted. The Yang di-Pertuan Negara held his office for four years and may be re-appointed from time to time.

11 - Council of Ministers to Cabinet
The Rendel Constitution provided for a Council of Ministers that consisted of the Governor (as President) and nine ministers. Of these, six were appointed from among the elected and nominated members of the Legislative Assembly while three members - the Chief Secretary, the Treasury Secretary, and the Attorney-General - were nominated by the Governor. In 1958, the Council of Ministers was transformed into a Cabinet that consisted of the Prime Minister 'and such Ministers as may be appointed' on the advice of the Prime Minister. With this change, the number of Ministers was no longer circumscribed by the Constitution.

12 - Ministerial Responsibilities
While the Rendel Constitution limited the number of Ministers to six, the 1958 Constitution left the number of Ministers in the Cabinet to the Prime Minister's discretion.

13 - Assistant Ministers
The post of Assistant Minister was specifically created under the Rendel Constitution. It empowered the Governor to appoint Assistant Ministers 'to assist Ministers in the discharge of their duties and functions' after consultation with the Chief Minister. This clause was the source of much contention when Chief Minister David Marshall tried to get Governor Robert Black to appoint additional Assistant Ministers. Black refused, arguing that the word 'may' in Art 32 meant that he had a personal discretion to disagree with the Chief Minister's recommendation, while Marshall argued that in this context, the word 'may' meant 'shall'. The matter was resolved by Colonial Secretary Sir Alan Lennox-Boyd backing Marshall's interpretation. It is no exaggeration that this constitutional crisis led to the holding of constitutional talks in 1956. The 1958 Constitution continued the tradition of including the post of Assistant Minister in Art 28. In this case, the wording of Art 28 made it clear that the Yang di-Pertuan Negara would appoint Assistant Ministers 'acting in accordance with the advice of the Prime Minister' thereby removing the ambiguity over the head of state's discretionary powers of appointment. The post of Assistant Minister cease to be mentioned in the Constitution
after 1963.

14 - Chief Minister to Prime Minister
The Chief Minister - who was 'appointed by the Governor acting in his discretion' - became in 1958, the all-powerful Prime Minister, in keeping with the traditions of Westminster. Under the Rendel Constitution, the British fully expected the Chief Secretary - who was appointed by the Governor - to act as the most senior among its Council of Ministers. The post of Chief Minister was originally called Leader of the House and was meant to apply to the member who commanded the confidence among the elected members of the Assembly. It was David Marshall - the first Chief Minister - who, by sheer force of personality and his forceful repudiation of colonialism, that catapulted the Chief Minister's position to something closer to that of Prime Minister. Indeed, the Chief Minister was not even expected to have his own office or staff, and was expected to be an ordinary Minister who ranked first among equals in terms of protocol. Indeed, the lack of an office for the Chief Minister led Marshall to threaten setting up an office and conducting state affairs 'under the old apple tree' across from what is now the Asian Civilizations Museum. This changed radically with the creation of the post of Prime Minister under the 1958 Constitution.

15 - Ex-Officio Ministers
Article 20 of the Rendel Constitution provided for the appointment of three Ex-Officio Ministers: the Chief Secretary, the Attorney-General, and the Financial Secretary. In 1955, these posts were held by William Allmond Codrington Goode, Edward John Davies and Tom Hart respectively. With the transformation of Singapore into a self-governing state, Ex-officio Ministers were made redundant and found no expression in the 1958 Constitution.

16 - State Advocate-General
Up till 1958, the Attorney-General had been a colonial appointee. Like in the United Kingdom, the Attorney-General acted more as law minister than as the government's lawyer and legal adviser. Under the 1958 Constitution, the post of Attorney-General ceased to exist. In its place, the Constitution provided for the appointment of a State Advocate-General with the power of criminal prosecution. The State Advocate-General was also allowed to hold the office of Permanent Secretary for the Ministry of Law. Singapore's first State Advocate-General was Ahmad bin Mohd Ibrahim, a Queen's Scholar who later achieved great distinction as a legal scholar. In 1965, the post was converted to that of Attorney-General and Ahmad continued as independent Singapore's first Attorney-General till 1967 when he resigned to migrate to Malaysia.

17 - Cabinet Secretary
The post of Cabinet Secretary was created to replace the Governor's Secretary and Clerk to the Council of Ministers. The Cabinet Secretary's primary responsibility is to arrange the business and keep the minutes of Cabinet meetings, and convey the decisions of the Cabinet to the appropriate persons or authority.

18 - Permanent Secretaries
The post of Permanent Secretary made its first appearance in the 1955 Rendel Constitution. The Governor was then empowered to appoint a Permanent Secretary for each ministry to supervise the department. Under the 1958 Constitution, the Prime Minister was responsible for the allocation of permanent secretaries to each ministry. Permanent secretaries were appointed by the Yang di-Pertuan Negara 'acting in his discretion but after consultation with the Prime Minister, from a list of names submitted by the Public Service Commission'.

19 - Composition of Legislative Assembly
The Rendel Constitution provided for a Legislative Assembly comprising 25 elected members and four nominated members. Under the 1958 Constitution, the Assembly was enlarged to 51 members, all of whom were elected.

20 - Elections
In both the 1955 and 1958 Constitutions, general elections must be held within three months of the Assembly being dissolved. The life of the Assembly under the Rendel Constitution was four years, but was extended to five years under the 1958 Constitution.

21 - Speaker
Under the Rendel Constitution, the Speaker of the Assembly could not be a member of the Assembly. It was envisaged that the Speaker would be totally neutral and non-partisan. However, under the 1958 Constitution, the Speaker could be elected by the Assembly, either from among its own members or from members outside the House. This practice remains in force today. Sir George Oehlers (1908-1968) was Speaker of the Assembly from 1955 to 1963. Upon his retirement, Oehlers became Speaker of the Sabah Legislative Assembly.

22 - Official Language/s
After being elected into office, the Labour Front government of David Marshall worked assiduously to create a multi-racial and tolerant society. One of its most visible achievements was the removal of the monopoly of English as the sole language of debate and proceedings, and having in its stead, four official languages representing the four major ethnic groups in Singapore: Malay, Chinese (Mandarin), Tamil and English.

23 - Qualification for Assembly Membership
The qualifications for membership in the Legislative Assembly were significantly altered with the passage of the 1958 Constitution. The previous need for citizenship of the United Kingdom and the Colonies was removed in favour of a Singapore citizenship. In view of the move to have four official languages in the Assembly, the requirement that the candidate be sufficiently proficient in English to take part in Assembly proceedings was enlarged and anyone who had sufficient proficiency in at least one of the four official languages would be eligible for membership in the Assembly.

24 - Disqualification for Membership
A specific ground for disqualification for membership of the Legislative Assembly under the 1958 Constitution was if a person owed an allegiance or adherence to a foreign power or state or is employed by any foreign power or state. This requirement was deemed necessary in 1958 as the issue of what is tantamount to Singapore citizenship was not yet settled. Under the current Constitution, the owing of allegiance to a foreign power is a ground for the deprivation of citizenship, thus rendering this disqualification unnecessary since only Singapore citizens are eligible to run for Parliament.

25 - Privileges of Members
Both the Rendel and 1958 Constitutions provide that the privileges of the Legislative Assembly and its members be determined by ordinary law, but that in no instance should 'such privileges, immunities or powers exceed those of the Commons' House of Parliament in the United Kingdom and of the Members thereof'. This is no longer a constitutional requirement although the Parliament (Privileges and Immunities) Act provides that 'privileges, immunities and powers of Parliament and of the Speaker, Members and committees of Parliament shall be the same as those of the Commons House of Parliament of the United Kingdom and of its Speaker, Members or committees at the establishment of the Republic of Singapore'.

26 - 'Citizen of Singapore'
While the phrase 'citizen of Singapore' was used in the 1958 Constitution, it was never defined. One would have had to consult the Citizenship Ordinance which provided that persons born in Singapore or the Federation of Malaya; or British citizens who had been resident for two years in Singapore, or those who were resident for ten years or more, would qualify for citizenship. Upon merger with the Federation of Malaysia, all Singapore citizens automatically became Malaysian citizens. The citizenship requirements were incorporated into Part III of the 1963 State Constitution, and the Citizenship Ordinance was consequently repealed.

27 - Filling of Vacancy
The 1958 Constitution made it clear that Parliament was to be the master of its own house and procedures, and thus provided that any vacancy shall be 'filled by election in the manner provided by or under any law for the time being in force in Singapore'. This allowed the Legislative Assembly, and now Parliament, to amend election rules without the need to trigger a constitutional amendment. The relevant law as it applied in 1958 was the Singapore Legislative Assembly Elections Ordinance 1954.

28 - Clerk of Assembly
For the first time, the constitution provided specifically for the staff of the Legislative Assembly and the office of the Clerk of the Assembly. These provisions remain in today's Constitution.

29 - Quorum of Assembly
Under the Rendel Constitution, the quorum for the Legislative Assembly was eight members out of 25. Since 1958, the quorum has been fixed at one quarter of the total membership of the House. This obviates the need to amend the Constitution every time the legislature is enlarged. It remains so today.

30 - Oaths of Allegiance
Under the 1958 Constitution, the Yang di-Pertuan Negara swore allegiance to Queen Elizabeth II of the United Kingdom while the Prime Minister, Ministers and Assistant Ministers swore allegiance to the Yang di-Pertuan Negara. This was the last Constitution requiring any office bearer in Singapore to swear allegiance to the British Crown.

31 - Voting and Division
Voting in the Legislative Assembly had always been by a majority. If there is an equal number of votes for and against the motion, the motion is deemed lost. In the 1958 Constitution, the Speaker has a right to vote if he is elected from among the members of the Assembly, but has no right to vote if he is elected from outside the Assembly's membership. The Speaker has no casting vote.

32 - Assembly Sessions
Assembly sessions were required to be held once in every year, not more than 12 months apart. This provision was similar to that contained in the Rendel Constitution. In today's Constitution, the period between parliamentary sessions cannot be longer than six months.

33 - Prorogation and Dissolution
Under the Rendel Constitution, the Governor was empowered to prorogue or dissolve the Assembly after consultation with the Chief Minister, or upon the expiration of four years from the date of the last general election. Prorogation and dissolution were treated separately in the 1958 Constitution. The Yang di-Pertuan Negara could prorogue the Assembly at any time. With respect to dissolution of the Assembly, the Yang di-Pertuan Negara will dissolve the Assembly if he is satisfied that no Member of the Assembly is 'likely to command the confidence of the majority of Members', or if he, acting in his discretion, is advised by the Prime Minister to do so. Finally, the Yang di-Pertuan Negara shall dissolve the Assembly at the expiration of five years from the date of the last general election.

34 - General Elections
General elections must be held within three months from every dissolution of the Assembly. This requirement first appeared in the Rendel Constitution and continues in today's Constitution.

35 - Internal Security Council ('ISC')
The ISC was a unique body created by the 1958 Constitution in preparation for Singapore's self-governing status where foreign affairs, defence and internal security remained in the hands of the British. One major sticking point in the 1956 Constitutional Conference was on the composition of this body. The British proposed a seven-man ISC with the British High Commissioner as its chairman. David Marshall objected vehemently and, at the very last moment, proposed equal membership of British and Singapore members and the inclusion of a representative from the Federation of Malaya who would act as chairman. This was roundly rejected by the British and an impasse ensued. During the 1957 Constitutional Talks, the British agreed to the inclusion of the Federation of Malaya's representative but insisted that the ISC be chaired by the British High Commissioner. This was agreed to and included in the 1958 Constitution. The ISC was responsible for ordering arrests under the Internal Security Ordinance 1960. The ISC ceased to exist with Singapore's entry into the Federation of Malaysia in 1963.

36 - Malayan Representative
The Internal Security Council was made up of: the British High Commissioner (Chairman); the Prime Minister of Singapore; two representatives of the Singapore government; two representatives of the British government; and a representative from the Federation of Malaya. The Malayan representative on the ISC was Tun Dr Ismail Abdul Rahman, Deputy Prime Minister of Malaya.

37 - Reserved Matters
As Singapore was now a self-governing state, only the defence and external affairs lay in the hands of the British. These matters were explicitly reserved under Art 72 of the 1958 Constitution. More significantly, the British government reserved the right to suspend the operation of the Constitution if it was 'satisfied' that the situation in Singapore was 'such as to threaten the ability of that government to discharge its responsibilities for defence and external affairs or that the Government of Singapore' had acted 'in contravention of the Constitution of Singapore'.

38 - Public Service Commission
The British had established a Civil Service Commission for the Straits Settlements in 1855 but it was not a permanent institution with significant powers. In 1947, the Public Services Salaries Commission of Malaya under the chairmanship of Sir Harry Trusted recommended the establishment of a permanent Public Services Commission and the Public Services Commission Ordinance was passed two years later. The Public Service Commission was deemed to be a very important body that would help ensure the quality of the civil service and to safeguard its integrity. In 1958, a whole new Part IX 'Public Services' was included in the Constitution.

39 - Judiciary
While Singapore was a colony, all matters pertaining to the establishment of the judiciary were covered by the Courts Ordinance 1873 and its subsequent amendments. It was only in 1958 that the relevant parts of the Courts Ordinance were incorporated in the Constitution. Article 87 established the Supreme Court consisting of a Chief Justice and such Puisne Judges as may be appointed from time to time. There was no limit on the number of Puisne Judges that could be appointed.

40 - Qualification of Judges
No person could qualify for appointment as a Judge of the Supreme Court unless he or she first qualified to practise as an advocate in a court in England, Scotland or Northern Ireland and had been so qualified for at least seven years. Today, the qualification for judgeship requires the judicial candidate to be a 'qualified person' within the meaning of the Legal Profession Act for at least ten years.

41 - Chief Justice and Puisne Judges
The Chief Justice was to be appointed by the Yang di-Pertuan Negara on the advice of the Prime Minister. This was the first time a local politician had any say in the choice of a Chief Justice. The Puisne Judges were also appointed by the Yang di-Pertuan Negara on the advice of a Council comprising the Chief Justice, substantive Puisne Judges and the State Advocate-General. Today, the Chief Justice is appointed by the President on the advice of the Prime Minister and Judges of the Supreme Court are appointed by the Yang di-Pertuan Negara on the advice of the Prime Minister, acting on the advice of the Chief Justice.

42 - Judges' Tenure and Terms of Office
Under the 1958 Constitution, judges hold office until the age of 62 years. A judge may be removed for inability to discharge his functions or for misbehaviour. A move to remove a judge could be initiated by the Prime Minister (in the case of the Chief Justice) or the Chief Justice in consultation with the Prime Minister (in the case of any other judge), by making a representation to the Yang di-Pertuan Negara that the judge in question be investigated for misbehaviour or inability to discharge his functions. The Yang di-Pertuan Negara would then appoint a tribunal consisting of a chairman and at least two other members who hold or have held office as a High Court judge 'in any part of Her Majesty's dominions'. If the tribunal recommends removal, the Yang di-Pertuan Negara would then request that the question of removal be referred to the Judicial Committee of the Privy Council who will make a recommendation on whether the judge in question should be removed. If removal is recommended, the Yang di-Pertuan Negara will remove the judge by Order under Public Seal. Today, a judge may be removed for misbehaviour or inability to discharge his functions only after a recommendation for removal is received from a five-judge tribunal.

43 - Legal Service Commission
To safeguard the integrity of the Legal Service, a separate Legal Service Commission ('LSC') was established under Art 93 of the 1958 Constitution. The Commission consisted of the Chief Justice (as President), the Chairman of the Public Service Commission; a Judge of the Supreme Court nominated generally or specially by the Chief Justice; the State Advocate-General, and no more than two members of the Public Service Commission nominated by the Chief Justice. Today, the LSC consists of the Chief Justice (as President), the Chairman of the Public Service Commission, the Attorney-General and at least three, but not more than six, members of whom one each is nominated by the Chief Justice, the Chairman of the Public Service Commission and the Prime Minister.

44 - Foreign Judges
Article 94 of the 1958 Constitution envisaged the employment of foreign judges to staff the Singapore Supreme Court. No foreign judges were ever appointed under this provision.

45 - Finance
Finance was incorporated as a separate and distinct subject into the Constitution for the first time in 1958 under Part XI. It covers, among other things, budget estimates, authorisation of expenditure, the Contingencies Fund, the Consolidated Fund and the Public Debt.

46 - Director of Audit
The new financial provisions created a new constitutional post - the Director of Audit, who was appointed by the Yang di-Pertuan Negara, acting on the Prime Minister's advice. The Director of Audit had security of tenure up till the age of 55 and was responsible for auditing the accounts of all departments and offices of the government. The position of the Director of Audit has been replaced by the Accountant-General. Under the present Constitution, the Accountant-General is appointed by the President (acting in his personal discretion), upon consultation with the Prime Minister, and holds office for a term of six years. He is eligible for re-appointment for further terms of six years each.

47 - Amendment of Constitution
The 1958 Constitution could be amended, augmented, revoked or replaced by the British government, acting on the advice of the Privy Council, provided that this power is not exercised without the concurrence of the Singapore government. The Legislative Assembly was also empowered to amend, augment, replace or revoke any provision of the Constitution provided that the amendment Bill be passed by at least two-thirds of all members of the Assembly at the final vote. Today, Parliament may amend the Constitution by passing the amending Bill by at least two-third votes at the Second and Third readings of the Bill.

48 - Suspension of Constitution
Under Art 106, the British government reserved the right to suspend the operation of the Constitution if it was 'satisfied' that the situation in Singapore was 'such as to threaten the ability of that government to discharge its responsibilities for defence and external affairs or that the Government of Singapore' had acted 'in contravention of the Constitution of Singapore'. The UK High Commissioner could then assume the government of Singapore by making a Proclamation to that effect. With the Constitution suspended, the High Commissioner would assume both executive and legislative powers. This provision was never invoked.

49 - Constitutional Supremacy
The 1958 Constitution makes no mention of the supremacy of the Constitution or of the power of the Court to undertake judicial review.

50 - Interpretation
Article 1(14) of the 1958 Constitution provided that in interpreting the Constitution, 'full regard shall be had to the duty of the Government of Singapore at all times to discharge the responsibilities' regarding the special position of the Malays and the interests of other minorities. In 1963, with the incorporation of the government's responsibility towards the Malays and racial and religious minorities incorporated into Art 89 of the 1963 Constitution, this interpretive clause became redundant and was thus deleted.

Kevin YL Tan
Professor (Adjunct), Faculty of Law,
National University of Singapore
E-mail: equilibrium@pacific.net.sg