SGHC Imposes Life Imprisonment for Heinous Child Abuse Case

The Singapore Court of Appeal in Dan v Public Prosecutor [2025] SGCA 45 has delivered one of its sternest condemnations of child abuse, enhancing the sentence of a father who brutally abused his children and caused the death of his five-year-old daughter.

The decision underscores how the judiciary views extreme breaches of parental trust as belonging to the “worst type” of culpable homicide cases, meriting the maximum sentence of life imprisonment.

What's The Matter?

The facts paint a harrowing picture. Over a period of nearly two years, the appellant subjected his two young children to repeated physical assaults, starvation, and prolonged confinement in inhumane conditions. The abuse culminated in a series of violent assaults in August 2017, during which the father punched, slapped, and stamped on his daughter, leading to her death. An autopsy revealed she was severely undernourished and bore multiple injuries across her body.

The father compounded his crimes by attempting to destroy evidence and misleading the authorities.

What Court Said?

At trial, he pleaded guilty to culpable homicide not amounting to murder under Section 304(a) of the Penal Code, four charges of ill-treatment of a child under Section 5 of the Children and Young Persons Act (CYPA), and a charge of disposing of evidence under Section 201 of the Penal Code.

The High Court imposed an aggregate sentence of 34.5 years’ imprisonment plus an additional six months in lieu of caning, as the appellant was medically unfit.

On appeal, however, the Court of Appeal went further. Chief Justice Sundaresh Menon, delivering judgment, held that the cruelty, prolonged duration of abuse, extreme vulnerability of the victim, and the father’s gross breach of parental duty placed the case among the most egregious instances of culpable homicide.

The court drew parallels with precedents such as Public Prosecutor v Azlin bte Arujunah and Public Prosecutor v Firdaus bin Abdullah, emphasising that where a parent’s betrayal of trust results in a child’s death, the law must respond with its most severe sanction.

Importantly, the Court also clarified sentencing principles. It reiterated that an appellate court retains the power to enhance sentences in the interests of justice, even absent a prosecution appeal, where the trial sentence is manifestly inadequate.

It rejected the argument that a guilty plea merited significant reduction, noting that the plea was entered only after overwhelming evidence emerged and could not reflect genuine remorse.

The “public interest exception” under the Plea Guidelines applied to deny any discount.

In consequence, the Court substituted the 15-year sentence for culpable homicide with life imprisonment. The other sentences, including the maximum terms for the CYPA offences, were left intact but ordered to run concurrently.

This case will stand as a landmark in Singapore’s sentencing jurisprudence on child abuse and culpable homicide. It affirms that life imprisonment is not reserved solely for murder but may be imposed where the conduct under Section 304(a) reaches the outer limits of culpability.

It also highlights the court’s broader role in ensuring that sentencing reflects society’s abhorrence of such atrocities and offers deterrence against the gravest parental betrayals.