149-607: The Hock Lee bus riots took place on 12 May 1955 in Singapore. The riots started as a result of confrontation between the police, bus workers of the Hock Lee Amalgamated Bus Company and students who supported the bus workers. In February of that year, the Hock Lee Amalgamated Bus Company fired 229 bus workers due to their association with the Singapore Bus Workers' Union. As a result, the bus workers went on
298-594: A monist view of law, public international law rules are not part of domestic law and cannot be enforced by the courts unless they have first been incorporated into domestic law in some way. Customary international law is defined in the Statute of the International Court of Justice as "evidence of a general practice accepted as law". Rules of customary international law can be declared by courts to be part of domestic law under certain conditions. However, they are not
447-544: A purposive approach , favouring interpretations that promote the purpose or object underlying constitutional provisions. Article 4 of the Constitution expressly declares that it is the supreme law of the land. The Constitution also appears to satisfy Albert Venn Dicey 's three criteria for supremacy: codification, rigidity, and the existence of judicial review by the courts. However, the view has been taken that it may not be supreme in practice and that Singapore's legal system
596-514: A "local conditions" rationale which prescribes reading the Constitution "within its own four walls and not in the light of analogies drawn from other countries such as Great Britain, the United States of America or Australia". This has been termed a conservative and restrictive approach that seems to undermine the court's duty to generously interpret fundamental liberties. However, it has been noted that this approach to constitutional interpretation
745-533: A Constable with the Volunteer Special Constabulary, who was severely beaten by a mob, Yuen Yau Phang, another Chinese police officer who was allegedly burned to death in his car, Gene D. Symonds, an American press correspondent also beaten by the mob and Chong Lon Chong, a sixteen-year-old student of Chin Kang School whose death caught the most attention. In an initial Straits Times report, the student
894-436: A claim for wrongful dismissal by a police sergeant, one issue arising was whether a constitutional provision introduced in 1970 had impliedly repealed an existing provision. Judicial Commissioner Chan Sek Keong decided the case on other grounds, but observed on an obiter basis that this argument was no longer relevant because only the 1970 provision appeared in the 1980 Reprint of the Constitution, and Article 155(3) of
1043-597: A communist subversion, as an Anti-Colonial Movement, and as a bottom up, spontaneous response to particular events. In the 1950s, the Chinese students were one of the largest groups involved in demonstrations. Their motivations have been consistently credited to communist manipulation – through a united front strategy . The united front strategy was a political tool employed by the Malayan Communist Party (MCP) with aims of regathering and rebuilding their strength, which
1192-610: A constitutional commission headed by Sir George Rendel was set up to recommend further changes in the constitutional system, with the aim of increasing widespread participation in the central and local government of Singapore. The British Government accepted most of the Rendel Commission's recommendations in its report of February 1954 and implemented them by way of the Singapore Colony Order in Council 1955, commonly known as
1341-527: A draw-down by transferring an equivalent sum from the current reserves to the past reserves. The principles adopted in the white paper remain binding unless either (or both) the Government or the President formally notifies the other that it no longer wishes to abide by them. Soft law has also been described by academics as a method of influencing communitarian conduct or even enforcing constitutional standards in
1490-570: A key moment in galvanising popular opposition to colonial rule. Following the end of the Japanese Occupation in 1945, the British sought to regain political control over Singapore, which was a vital strategic centre to them. The British Military Administration was set up, focusing on the reorientation of the state in order to meet post-war crises. The British set sights to bolster social and economic life, and to secure their footing in Singapore. Of
1639-478: A legislative judgment, and legislation which is "of so absurd or arbitrary a nature that it could not possibly have been contemplated by our constitutional framers as being 'law' when they crafted the constitutional provisions protecting fundamental liberties", would violate Article 9(1) , despite the provision not explicitly referring to this. In some cases, the courts have also demonstrated an unwillingness to consult foreign constitutional case law, and have crafted
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#17328692811171788-599: A method of informal regulation against the backdrop of existing legislation. Soft constitutional law can also serve as principles of engagement between institutions. One example is the 1999 white paper entitled The Principles for Determining and Safeguarding the Accumulated Reserves of the Government and the Fifth Schedule Statutory Boards and Government Companies , which contains non-exhaustive principles for shaping institutional interactions between
1937-528: A more efficient transportation system. To many of the workers, these strikes helped them to gain a 'Singaporean' consciousness outside of colonialism. The strikes and the workers' sentiments however were quickly put out. Part of Singapore's modernisation project was to expand its tourism sector and an efficient transportation system was important for this growth. This did not leave room for any form of activism that would disrupt Singapore's necessary path towards modernity and economic development. Media interest in
2086-565: A national referendum by at least two-thirds of the total number of votes cast. This requirement also applies to Articles 5(2A) and 5A, though these provisions are not yet operational. Article 5(2A) protects certain core constitutional provisions such as the fundamental liberties in Part IV of the Constitution, and Articles relating to the President 's election , powers , maintenance , immunity from suit, and removal from office; while Article 5A enables
2235-508: A norm. According to British jurist and constitutional theorist Albert Venn Dicey , three legal criteria must be satisfied before a constitution can claim to be supreme: Although Article 4 of the Singapore Constitution expressly declares that it is the supreme law of the land and the Constitution appears to satisfy Dicey's criteria, the view has been taken that it may not be supreme in practice and that Singapore's legal system
2384-661: A number of laws having constitutional status have applied to it. Singapore became part of the Straits Settlements in 1867, which were granted a colonial constitution by way of letters patent dated 4 February 1867 that established the Legislative Council of the Straits Settlements . Further letters patent dated 17 November 1877 set up an executive council and authorised the Governor to appoint judges. Thereafter,
2533-402: A number of other legal instruments were issued to streamline the constitutional structure of the colony, but did not make significant changes to the arrangements put in place by the 1867 and 1877 letters patent. The last constitution of the Straits Settlements was based on letters patent dated 17 December 1911 as amended by letters patent and royal instructions both dated 18 August 1924. After
2682-450: A practising lawyer, to defend the seven students who were charged for obstructing the police on 13 May 1954. Prior to this, Lee was also involved in fighting the case for the Fajar 8. Although the seven students were eventually still sentenced to three months imprisonment, this episode allowed Lee to build connections with the Chinese (especially the students and trade union workers), a group that
2831-421: A realm for the exercise of legitimate governmental power". A constitution can therefore be described as "[t]he fundamental and organic law of a nation or state, establishing the conception, character, and organization of its government, as well as prescribing the extent of its sovereign power and the manner of its exercise", or a specific statute containing provisions that serve those purposes. In this article,
2980-477: A rival yellow union and hired 200 new workers in the process. Feeling threatened, on 22 April 1955, the bus workers' union put up a notice to strike. The company proceeded to fire 229 workers who were related to the SBWU on 24 April 1955. This angered the workers further which prompted them to set up human blockades at the bus depot, stopping the buses from leaving. Chief Minister David Marshall tried to plead their case with
3129-536: A simple majority of the New Zealand Parliament , "any government intent on repeal or restrictive amendment of the Bill of Rights is likely to suffer extreme political difficulty and opprobrium". In order to safeguard minority interests in a newly independent Singapore and contain the communist threat of the time, a constitutional commission chaired by Chief Justice Wee Chong Jin was convened in 1966 to review
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#17328692811173278-459: A single, composite document". To achieve this task, the Attorney-General was given discretion to merge the existing provisions of the two Constitutions and make modifications that might be necessary or expedient due to Singapore's independent status; to rearrange the provisions; and to omit duplicated, inappropriate or inapplicable ones, among other things. Pursuant to this, the 1980 Reprint of
3427-657: A source of constitutional law, because the Court of Appeal held in Yong Vui Kong that such rules can only be declared as part of the common law and cannot be directly incorporated into the Constitution. Unless an international treaty entered into by the Singapore Government has been given effect through an Act of Parliament, it cannot be enforced as domestic law by the courts. Nonetheless, such international obligations exert an influence on constitutional interpretation as
3576-415: A strike. Despite mediation efforts, the strikes escalated into riots on 12 May, resulting in the deaths of four people and thirty-one people injured. The global trend of decolonisation, led the way for the liberalisation of Singaporean politics. The 1948 constitution that reformed the political and judicial systems in Singapore paved the way for Singapore's first elections in 1948. This partial liberalisation
3725-586: A subtle manner. One example is the issuance of the Declaration of Religious Harmony in 2003, which was proposed by Prime Minister Goh Chok Tong in October 2002 following a series of domestic events which had heightened racial and religious sensitivities. Constitutional conventions are unwritten political customs which aid the smooth operation of the government. They are characterised as "rules of constitutional behaviour" which are "binding by and upon those who operate
3874-469: A valuable political force and worked towards systematically absorbing them into the communist movement. Second, during this period of time, members of the Town Committee (a secret organisation operating underground as the executive arm of the Malayan Communist Party, with its mobile headquarters on the borders of Malaya and Thailand) were arrested, leaving only the cells in charge of propaganda, and cells in
4023-411: Is de facto characterised by parliamentary sovereignty . Dicey's first legal criterion for a constitution to be regarded as supreme is that it must be written. This requirement is necessary for the precise identification of constitutional provisions, which makes it more convenient for Parliament to make constitutional amendments, and provides the judiciary with a basic text against which to determine
4172-564: Is de facto characterised by parliamentary sovereignty . There are two ways to amend the Constitution, depending on the nature of the provision being amended. Most of the Constitution's Articles can be amended with the support of more than two-thirds of all the Members of Parliament during the Second and Third Readings of each constitutional amendment bill . However, provisions protecting Singapore's sovereignty can only be amended if supported at
4321-585: Is completely immutable. If the Constitution is static, the nation's political development may be stunted. Instead, rigidity of the Constitution merely contemplates that compared to ordinary legislation, the Constitution should be more difficult to amend. 1954 National Service riots In December 1953, the British colonial government in Singapore passed the National Service Ordinance , requiring all male British subjects and Federal citizens between
4470-693: The Fajar Publication . According to Loh (2013), this particular issue, dated 10 May 1954, and titled as "Aggression in Asia", was one that involved critical views on the ongoing Anglo-American Military initiative to form the Southeast Asia Treaty Organisation (SEATO). In addition, the issue also contained comments on the National Service Bill which was passed in Singapore earlier on. It argued that pressing students into military service
4619-556: The Japanese Occupation , the Straits Settlements were dissolved in 1946 and Singapore became a Crown colony . Its new constitution, the Singapore Order in Council 1946, established an executive council and a legislative council which, for the first time, had a number of elected members. The constitution came into effect on 1 March 1948, and the first legislative elections in Singapore were held on 20 March that year. In 1953,
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4768-863: The Rendel Constitution was accepted by the British government and resulted in elections that brought David Marshall and the Labour Front party into power. This new constitution led to the provisional easing of restrictions under Emergency regulations, which in its turn sparked off much interest in politics among the people living in Singapore. This renewed liberalisation led to the establishment of many trade unions during this period which would have alarmed many employers that were worried about their business interests. Oppressive colonial educational and labour policies discriminated against Chinese students and workers. Perceived unjust colonial policies led to various episodes of labour unrests in 1954 and 1955. In 1954 there
4917-457: The second and third readings of a constitutional amendment bill . The requirement of a two-thirds majority for amendment was only restored in 1979. The justification for the reversion given by the Minister for Law , E.W. Barker , was that "[a]ll consequential amendments that have been necessitated by our constitutional advancement have now been enacted". However, these amendments were made to
5066-565: The 1950s saw more intense left-wing activities, for example, the Hock Lee Bus riots. 13 May 1954 also has a crucial significance in the politics in Singapore, for it was this event that enforced unity between students, labour workers and the People's Action Party (PAP), then led by Lee Kuan Yew and leftist trade union leaders Lim Chin Siong and Fong Swee Suan . The Chinese students' engaged Lee, then
5215-501: The 1963 State Constitution. In its report, the Wee Commission made recommendations regarding two broad areas – political philosophy and principles, and various governmental institutions. Many, but not all, of the recommendations were adopted by Parliament. In 1980, provisions from the three documents referred to above were consolidated into a single reprint for the first time. Containing 162 Articles and three schedules, this reprint
5364-519: The 1963 State Constitution; the amendment Acts were silent on whether they applied to the RSIA. Thus, although Parliament has made no attempt to amend the RSIA since 1965, it can theoretically be changed or even repealed by a simple majority in Parliament. One problem this raises is even though the RSIA is categorised by the Government as a "constitutional document", legally speaking it is apparently not part of
5513-646: The British's plan to consolidate and maintain rule following the Japanese occupation. In December 1953, the National Service Ordinance was passed, requiring the registration of all male British subjects and Federal citizens between the ages of 18-20 for part-time military training. After the announcement was made regarding the National Service draft, personnel involved were to register for the call-up from 8 April to 12 May 1954. By 12 May 1954, students from
5662-481: The Chinese High School on 2 June 1954. This time, students requested for the postponement of call-up for National Service. Though, the lack of response from the government saw the students going on hunger strike on 15 June. The students only dispersed on 24 June. Constant negotiations were made back and forth between the students and the government in the following days. However, due to the resistance put up by
5811-501: The Chinese Middle School, intact. The propaganda sector consisted of few people, but the student sector had many members. Thus, it was the student sector which had the manpower to launch the open united front struggle when the time came. However, in order to mobilise and arouse the students, an issue had to be capitalised upon. The National Service Ordinance was chosen to serve this purpose. In Lee's book, he also mentioned that in
5960-605: The Chinese Middle Schools still did not register themselves for National Service (NS). In light of the impending deadline for registration and with requests from the Chinese students, Chief Secretary William Goode would meet representatives from the affected student body in the government house on 13 May 1954. This day however, resulted in a clash between Chinese Middle School students and riot squads. More than two dozen were reportedly injured and nearly 50 students were arrested. Of those arrested, 7 were convicted of obstructing
6109-421: The Chinese community and the British authorities. Anger and anti-colonial resentments were felt within the Chinese community, for English language represented colonial domination. In 1954, both the Chinese leadership and student activists faced further pressures when the British made English the only language to be used in the legislative assembly. The Chinese middle school students had however, also moved out of
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6258-471: The Chinese inter-schools sports competition — just a 30-minute walk away at Jalan Besar Stadium via Serangoon Road and Bukit Timah Road. The students were there to await the outcome of the meeting, and it was not a planned protest. In the days following 13 May 1954, tensions arose due to the "difficulties posed to the students by the Governor", when all that the students wanted was a form of written assurance for
6407-580: The Chinese owned bus companies. Shortly after the Hock Lee workers' strikes, the Singapore Traction Company strikes occurred which motivated the Hawkins Report of 1956. The Hawkins Report called for the reformation of the transportation industry in Singapore through a consolidation of the Chinese bus companies. The Hawkins report advocated for a single entity to control transportation. The report
6556-404: The Constitution and blurring the line between constitutional law and ordinary legislation. The second legal criterion is that the constitution must be rigid. This is important to ensure that constitutional provisions can only be changed by an authority that is higher in status than the ordinary legislative body existing under the Constitution. However, rigidity does not mean that the Constitution
6705-410: The Constitution and other legislation is adhered to, is an inappropriate forum. The Members of Parliament are freely elected by the people of Singapore. They represent the interests of the constituency who entrust them to act fairly, justly and reasonably. The right lies in the people to determine if any law passed be [ sic : by] Parliament goes against the principles of justice or otherwise. This right,
6854-568: The Constitution by exercising constituent power, the amendment Act cannot be challenged as inconsistent with the Constitution's existing provisions. The Singapore position is unclear since this issue has not been raised before the courts. However, it is arguable that they are likely to apply the Malaysian position as the relevant provisions of the Constitution of Malaysia and the Singapore Constitution are in pari materia with each other. In addition,
7003-489: The Constitution dealing with fundamental liberties suggests a parliamentary intention to give courts the discretion "to interpret the Constitution based on prevailing social conditions". It may also be noted that although the court may depart from previously held constitutional interpretations, it cannot disregard the text entirely. The courts have been willing to uphold the spirit of the Constitution by recognising fundamental constitutional principles not expressly mentioned in
7152-431: The Constitution is part of its responsibility: The court has the power and duty to ensure that the provisions of the Constitution are observed. The court also has a duty to declare invalid any exercise of power, legislative and executive, which exceeds the limits of the power conferred by the Constitution, or which contravenes any prohibition which the Constitution provides. Judicial attitudes inextricably shape and mould
7301-438: The Constitution is written". However, in Singapore not all legal rules having constitutional effect appear to be part of the Constitution. For example, white papers that contain quasi-constitutional principles would be extra-constitutional documents. By issuing such white papers, the Government may also trying to set guidelines on how the Constitution should be interpreted. Jaclyn Neo and Yvonne Lee view such documents as diluting
7450-471: The Constitution may serve constitutional functions and therefore be regarded as "essential to the workings of small-c constitutions". The Constitution itself empowers Parliament to enact laws for certain purposes. For instance, Article 17(2) states that "[t]he President shall be elected by the citizens of Singapore in accordance with any law made by the Legislature". To regulate such elections, Parliament passed
7599-634: The Constitution of Singapore are derived from the Malaysian Federal Constitution. This was effected through section 6(1) of the Republic of Singapore Independence Act 1965, which states that the provisions of the Constitution of Malaysia, other than those set out in section 6(3) of the Act, "shall continue in force in Singapore, subject to such modifications, adaptations and qualifications and exceptions as may be necessary to bring them into conformity with
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#17328692811177748-584: The Constitution of the State of Singapore 1963, the Federal Constitution of Malaysia made applicable to Singapore by the Republic of Singapore Independence Act 1965, and the Republic of Singapore Independence Act itself. These provided the newly independent nation with a working constitution at short notice. Since Singapore was founded as a factory or trading post of the East India Company in 1819,
7897-435: The Constitution was issued. In addition, the President was empowered to authorise the Attorney-General to publish further reprints incorporating all constitutional amendments in force at the date of the authorisation. While some commentators have noted that the 1980 Reprint created theoretical issues, to date no practical problems have arisen in the application of the Constitution. In Heng Kai Kok v. Attorney-General (1986),
8046-518: The Constitution", but are not legally enforceable. Such conventions which are consistently practised and not flouted become an intrinsic part of the constitution over time. However, since Singapore now has a written constitution, conventions play a much less significant role. In comparison, countries such as the United Kingdom which lack a written constitution derive a major part of constitutional law from conventions. Back in Singapore's colonial days,
8195-473: The Constitution. Additionally, the courts have read into the Constitution extratextual principles which either have the effect of expanding or limiting the ambits of fundamental liberties. In Ong Ah Chuan , the Privy Council held that references to the word law in clauses such as Article 9(1) and Article 12(1) of the Constitution include "fundamental rules of natural justice ", which were later held by
8344-465: The Constitution. In the exercise of its original jurisdiction – that is, its power to hear cases for the first time – the High Court carries out two types of judicial review: judicial review of legislation , and judicial review of administrative acts . Regarding the former, Article 4 of the Constitution states: "This Constitution is the supreme law of the Republic of Singapore and any law enacted by
8493-510: The Court of Appeal has held that "the Singapore Constitution[ ;] should, as far as possible, be interpreted consistently with Singapore's international legal obligations". However, it would not be appropriate for courts to refer to an international human rights norm if it does not accord with the way the constitutional text is worded, or if the history of the Constitution shows there was an intention to specifically exclude such
8642-448: The Court of Appeal to be procedural rather than substantive in nature. On the other hand, the courts have said that freedom of speech must be balanced against the right of other people to be free from offence, and have restricted freedom of religion in favour of "the sovereignty, integrity and unity of Singapore" which were said to be "undoubtedly the paramount mandate of the Constitution". Some ordinary statutes which are not part of
8791-417: The Government "made it a practice to always seek the President's views whenever it intends to move Constitutional amendments that affect the relevant provisions" concerning his discretionary powers. It has also been said that by convention it is a well-accepted practice that the President engages in charitable and community welfare work without government objection. As Singapore adopts a dualist rather than
8940-496: The Government adopted many constitutional conventions from the United Kingdom. After independence, an attempt was made to incorporate many of these Westminster conventions into the new written constitution. For example, section 3 of the Parliament (Privileges, Immunities and Powers) Act – the Act was enacted pursuant to Article 63 of the Constitution ;– states that the privileges and immunities of Parliament are to be
9089-489: The High Court declined to hold that there is any constitutional right to be informed of one's right to counsel as the Constitution does not expressly mention such a right. Chief Justice Yong Pung How held: Any proposition to broaden the scope of the rights accorded to the accused should be addressed in the political and legislative arena. The Judiciary, whose duty is to ensure that the intention of Parliament as reflected in
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#17328692811179238-460: The High Court has rejected the basic structure or basic features doctrine developed by the Supreme Court of India , which means that Parliament is not precluded from amending or repealing any provisions of the Constitution, even those considered as basic. Constitutionalism has been described as being "concerned with curbing oppressive government and preserving individual freedom while retaining
9387-569: The Hock Lee bus workers. C. M. Turnbull saw the cause of the riots to be a battle between moderate and left-wing politics within the People's Action Party (PAP) and attributed the workers' involvement to be one of "joint direct militant campaign of obstruction and violence." The book Men in White also frames the Hock Lee event as a "demonstration of the ruthlessness of the communists and their capacity to unleash violence in Singapore." In both these accounts,
9536-444: The Hock Lee incident were also due to anxieties felt by these two groups as a result of the conditions of colonial society. The Hock Lee bus workers' strikes can also be seen as one of the catalysts for the modernisation of the bus transportation industry in Singapore. The Hock Lee workers' strikes as well as other similar transportation workers' strikes resulted in the nationalisation of the Singapore transportation industry, specifically
9685-504: The Legislature after the commencement of this Constitution which is inconsistent with this Constitution shall, to the extent of the inconsistency, be void." In Tan Eng Hong v. Attorney-General (2012), the Court of Appeal held that although the Article only refers to laws enacted after the Constitution's commencement on 9 August 1965, laws which pre-date the Constitution can also be invalidated by
9834-599: The Legislature by law to determine and regulate the privileges, immunities or powers of Parliament", and Parliament has done so by enacting the Parliament (Privileges, Immunities and Powers) Act. Thio Li-ann has suggested that other Acts which have constitutional significance include the Internal Security Act and the Supreme Court of Judicature Act. Soft constitutional law refers to a written set of non-binding precepts which exert some degree of legal influence in
9983-582: The National Service Ordinance was actually supported by the Chinese, based upon Chinese press reports that recalled the heroic defence of Singapore by volunteers in 1942. Community leaders also praised the ordinance and called upon the Chinese community to fulfill their task of defending the country." Thum bases his opinion largely from Chinese sources such as the Nanyang Siang Pao, Nanfang Evening Post and Sin Chew Jit Poh . In Thum's view, "13th May 1954"
10132-488: The Parliament and a strong presumption of constitutional validity . Such conservatism is reflected in the courts construing fundamental liberties narrowly in certain cases. For instance, in Rajeevan Edakalavan v. Public Prosecutor (1998), even though Article 9(3) of the Constitution states that "[w]here a person is arrested, he ... shall be allowed to consult and be defended by a legal practitioner of his choice",
10281-402: The President and the Government concerning the exercise of the President's discretionary financial powers . One procedural guideline, which is not expressed in the Constitution, requires the President to inform the Government of his intention to gazette his opinion that one of its proposed transactions draws down on the nation's past reserves , to give the Government an opportunity to avoid such
10430-541: The President to veto proposed constitutional amendments that directly or indirectly circumvent or curtail his discretionary powers. These provisions are not yet in force as the Government views the Elected Presidency as an evolving institution in need of further refinements. The Malaysian courts have distinguished between the exercise of "constituent power" and "legislative power" by Parliament. When Parliament amends
10579-565: The Presidential Elections Act. Similarly, the Parliamentary Elections Act fulfils the requirements of Article 39(1), which provides that Parliament consists, inter alia , of elected Members of Parliament (MPs) and Non-constituency Members of Parliament (NCMPs) who have been elected according to the procedure prescribed in a law made by the Legislature. In addition, Article 63 states that "[i]t shall be lawful for
10728-547: The Rendel Constitution. While the new Legislative Assembly was a largely elected body, the colonial administration retained authority over administration, finance, internal security and law. The next stage in Singapore's constitutional development was its transformation from a colony to a self-governing state of the British Empire . This was effected by the Singapore (Constitution) Order in Council 1958, which created
10877-452: The Reprint states that "[a]ny reprint of the Constitution ... shall be deemed to be and shall be, without any question whatsoever in all courts of justice and for all purposes whatsoever, the authentic text of the Constitution of the Republic of Singapore in force as from the date specified in that reprint until superseded by the next or subsequent reprint". A revised edition of the Constitution
11026-475: The Republic of Singapore Independence Act itself. The text of the Constitution is one of the legally binding sources of constitutional law in Singapore, the others being judicial interpretations of the Constitution, and certain other statutes. Non-binding sources are influences on constitutional law such as soft law , constitutional conventions , and public international law . In the exercise of its original jurisdiction – that is, its power to hear cases for
11175-550: The actions of the bus company. The above conventional accounts commonly attribute the student involvement to be one of communist action and again do not give the students any form of political consciousness. The students who were involved in the riots were part of the Singapore Chinese Middle School Student Union (SCMSSU). The relationship between the workers and the students is one that is often overlooked in many accounts of history and thus leading to
11324-406: The affected student body in the government house on 13 May 1954. On 13 May 1954, students gathered to present their petition to Chief Secretary William Goode. However, the peaceful demonstration turned into a clash between the police and students. More than 2 dozen people were injured and 48 students were arrested. The demonstration of 13 May 1954 was followed by further demonstrations and proved
11473-453: The ages of 18–20 to register for part-time National Service. The deadline for registration was on 12 May 1954 and those who failed to register would be either jailed or fined. On 12 May 1954, students from the Chinese Middle Schools did not register themselves for National Service. In light of the impending deadline for registration and with requests from the Chinese students, Chief Secretary William Goode would later meet representatives from
11622-542: The approach applies to constitutional interpretation as well. It stated: "It is well established ... that a purposive interpretation should be adopted in interpreting the Constitution to give effect to the intent and will of Parliament". The generous approach to constitutional interpretation mentioned in Ong Ah Chuan might be said to accord with the purposive approach because the use of broad and general language in Articles of
11771-403: The boy was dead or still alive after he was shot. Furthermore, it was also established after the trial that the four men who were arrested were not students. The riot resulted in the deaths of four people and thirty-one people injured. While the Hock Lee incident has conventionally been portrayed be one of communist subversion, other sources suggest that the students and workers' involvements in
11920-531: The bus workers were not given any political consciousness as the event is seen as a spontaneous one that was initiated by the communists that eventually went out of control. Workers in the 1950s were subject to the many effects of colonial society. The Rendel Constitution paved the way for the liberalisation of Singapore politics coupled with the workers increasing anxiety about wages and working conditions as seen from an increase from 11 trade unions in 1946, to 236 unions in 1955. The post-war colonial administration
12069-465: The classrooms, leaving students outraged and refusing to register for national service. This episode was repeated again on 23 April 1954 at the Chinese High School. On 13 May 1954 itself, representatives from the affected students made preparations to meet William Goode in government house to negotiate the ordinance. The crowd (approximately 1000 people) that assembled in the vicinity of the government house to give their support were actually students from
12218-404: The colonial perspective and concludes that the students' involvement in the Hock Lee incident was part of a larger plan of communist subversion. Bloodworth starts his narrative by accusing the 'communist' students of being at the centre of the violence that occurred in the Hock Lee event. He attributes the cause of the unrest to union leader, Fong Swee Suan and takes on a perspective which favours
12367-455: The common conclusion that students' involvement was part of a violent extremist movement. The British adopted a substitution strategy to replace Chinese schools with English institution. A ten-year education plan unveiled by the colonial administration in 1949 sought to significantly decrease student enrolment in Chinese vernacular schools. Chinese students were faced with the implementation of high school exams that served little purpose in ensuring
12516-418: The communist threat in Singapore necessitates the polarisation of the scholarship on Singapore history and suggests that historians should take sides. Conventional historical narratives have represented the workers and students actions as violent and conceived out of communism. The emerging work on the Hock Lee incident have foregrounded the experiences of the people through the provision of accounts that focus on
12665-412: The company's management, but his efforts were futile. On 12 May 1955, multilateral talks to mediate the workers' disputes were hampered as police clashed with strikers. The clash involved an estimated 2,000 people which broke out in the streets of Alexandra Road and Tiong Bahru. The police tried to break up the 2,000 students and strikers using tear gas. Four people died as a result, including Andrew Teo,
12814-507: The consolidated Constitution. Constitutional scholar Dr. Kevin Tan has suggested it should be recognised as a sui generis Act having a unique status. It may be that the RSIA's status is similar to that of the New Zealand Bill of Rights Act 1990 , which is also an ordinary Act of Parliament . It has been said that while it is theoretically possible to amend or repeal the Bill of Rights Act by
12963-470: The constitutionality of any ordinary legislation. Without a written constitution, judicial review would almost be counter to the doctrine of separation of powers as judges would get to decide the contents and wording of the Constitution. In Marbury v. Madison , the US Supreme Court held that "the powers of the legislature are defined and limited; and that those limits may not be mistaken, or forgotten,
13112-529: The convergence of notions of nationalism, with help from the English-educated. The student resistance was very focused and uncompromising. It was evident that they were pushing the boundaries as far as the emergency regulations would allow, and anti-colonialism was the main engine driving their cause. The riot can also be explained as a spontaneous response to events surrounding the National Service Ordinance. Singaporean historian, Thum Ping Tjin , argues that
13261-411: The course of 1955-1956. The Hock Lee Amalgamated Bus Company was one of the eleven Chinese bus companies in Singapore that was in operation. In February 1955, the workers started their own union and joined with the Singapore Bus Workers' Union (SBWU), hence the company instantly fired the organisers of the union in an attempt to dissolve the union. On February 24, the company went a step further to set up
13410-425: The court. In addition, Article 162 provides that ordinary laws that were in force prior to the Constitution coming into force on 9 August 1965 continue to apply after the Constitution's commencement but must be construed with such modifications, adaptations, qualifications and exceptions as may be necessary to bring them into conformity with the Constitution. Thus, the Constitution reflects the principle established in
13559-452: The courts are to accord them "a generous interpretation ... suitable to give to individuals the full measure of the fundamental liberties referred to". However, it has been said that the Singapore judiciary has a conservative attitude when interpreting the Constitution as it seems to be "more protective of executive interests than individual freedoms". This is in line with the locally held judicial philosophy which features deference to
13708-420: The creation of many prospective student leaders, who were to be supported and become future pillars of the student movement. This statement was drawn from unpublished statements of ex-detainees. 13 May 1954, as Communist subversion, was seen in the context of the cold war and in supporting this position, sources from scholars such as Lee (1996) and Singh (2008) are largely drawn from colonial media. Following
13857-480: The declaration of emergency in 1948, the political instability left in Singapore grew vastly, both in size and power in 1954. This was attributed to large levels of economic exploitation and the social injustice felt by the people, which then saw subsequent calls for self-governance and democracy. This was especially so for the Chinese when the decision was made by the British to prioritise English-medium education over vernacular education. That resulted in friction between
14006-489: The drama The Journey: Tumultuous Times . Constitution of Singapore The Constitution of the Republic of Singapore is the supreme law of Singapore . A written constitution , the text which took effect on 9 August 1965 is derived from the Constitution of the State of Singapore 1963, provisions of the Federal Constitution of Malaysia made applicable to Singapore by the Republic of Singapore Independence Act 1965 ( No. 9 of 1965, 1985 Rev. Ed. ), and
14155-408: The enactment of this Act and in consequence of the independence of Singapore upon separation from Malaysia". This power lasted from 1965 to 1968. The Constitution (Amendment) Act 1965, which was enacted on the same day as the RSIA and also came into force on 9 August 1965, made the 1963 State Constitution amendable by a simple majority – that is, more than 50% – of all the Members of Parliament on
14304-585: The event sparked off some public debate. The Singapore Broadcasting Corporation 's television series Diary of A Nation , produced in 1988, covers the Hock Lee event in episode ten. The Hock Lee incident was also depicted in Channel News Asia 's documentary feature on violence and communism in Singapore in the 1950s, Days of Rage . A reaction to the film was published in the form of a three-part critique named, "Hock Lee bus riots – fact or fiction by CNA?" by The Online Citizen . The riots were also dramatised in
14453-463: The eyes of the communists themselves, the agitation over national service was a great success. Lee made this statement based on a following comment by Ng Meng Chang (a student cadre): .... said that the tremendous success of the May 13 incident was beyond expectation... this was the most successful student struggle ever since the emergency regulations... Lee also concluded by saying that the incident had seen
14602-601: The first time – the High Court carries out two types of judicial review: judicial review of legislation , and judicial review of administrative acts . Although in a 1980 case the Privy Council held that the fundamental liberties in Part IV of the Constitution should be interpreted generously, Singapore courts usually adopt a philosophy of deference to Parliament and a strong presumption of constitutional validity , which has led to fundamental liberties being construed narrowly in certain cases. The courts also generally adopt
14751-406: The government when all they wanted was to seek clarifications regarding National Service. In addition, miscommunication and translation regarding the term "National Service" resulted in adverse sentiments among these Chinese Middle School students for it was mistranslated as minzhong fuwu , 民众服务, which literally meant "servitude by the masses", a term with demeaning connotations implying the mass of
14900-667: The independent status of Singapore upon separation from Malaysia". Notably, the fundamental liberties in Part II of the Federal Constitution were made applicable to Singapore. However, Article 13 of the Federal Constitution which concerns the right to property , was specifically omitted to ensure the constitutionality of the Land Acquisition Act 1966 which authorises the Government to compulsorily acquire real estate . The Republic of Singapore Independence Act 1965 (RSIA)
15049-601: The introduction of the Nominated Member of Parliament (NMP) scheme, the First Deputy Prime Minister and Minister for Defence , Goh Chok Tong , noted that the select committee tasked to look into the issue had considered whether NMPs should be required to sever any ties they had with political parties and decided that it was unnecessary as it was "far better to leave ... conventions and practice to evolve". In 2007, Law Minister S. Jayakumar declared that
15198-482: The landmark decision of the Supreme Court of the United States , Marbury v. Madison (1803): since it is the role of the courts to interpret the law, they have power to decide whether ordinary laws are inconsistent with the Constitution and, if so, to declare such laws to be void. In the 1994 case Chan Hiang Leng Colin v. Public Prosecutor the High Court adopted a similar stance, and also affirmed that declaring void administrative actions and decisions that infringe
15347-466: The layman is ... to ascertain what a Constitution says". In 1979, Parliament amended the 1963 State Constitution to give authority to the Attorney-General of Singapore to "cause to be printed and published a consolidated reprint of the Constitution of Singapore, as amended from time to time, amalgamated with such of the provisions of the Constitution of Malaysia as are applicable to Singapore, into
15496-481: The legislative and executive bodies of government remained much the same as those in the 1958 Order in Council. On the other hand, the judiciary was regarded as a federal matter and did not form a part of the State Constitution. At this time, there was no bill of rights in the 1963 State Constitution, as the fundamental liberties in Part II of the Federal Constitution applied to Singapore. Certain provisions of
15645-456: The ones chosen by us to address our concerns. This is especially so with regards to matters which concern our well-being in society, of which fundamental liberties are a part. On the other hand, in Yong Vui Kong v. Public Prosecutor (2010) decided 12 years later, the Court of Appeal held that colourable legislation which purports to enact a 'law' as generally understood but which is in effect
15794-622: The parameters of strictly Chinese-focused issues by linking themselves to a larger historical context of anti-colonial movement. The Chinese students, together with the Socialist Club members of the University of Malaya, identified themselves with the students of China, India, and Indonesia who also played a role in their country's liberation. Both the English and Chinese-educated students were seen to be working together to resist colonial rule, and that
15943-485: The people acting as indentured servants of the elite. This discontent and miscommunication was further fuelled by the ineffective registration process whereby Chinese Middle School students were provoked by the disruptive and authoritative conduct of the government team, who sent teams into Chung Cheng High School without warning, and went from class to class to distribute registration forms, disrupting lessons. Teachers who refused to halt their lessons were also forced to leave
16092-399: The people exercise through the ballot box. The Judiciary is in no position to determine if a particular piece of legislation is fair or reasonable as what is fair or reasonable is very subjective. If anybody has the right to decide, it is the people of Singapore. The sensitive issues surrounding the scope of fundamental liberties should be raised through our representatives in Parliament who are
16241-410: The period of 1950 and 1955. Workers like Lee Tee Tong, who were subject to poor working conditions and the harsh realities of the colonial political economy led them to be increasingly unhappy with the government. This led to unrest among the workers as many were struggling to make ends meet. These strikes proved to be effective as the wages of workers increased by about 10 per cent on an hourly basis over
16390-497: The petition was again, returned to the students with the instruction that petitions from students should be submitted through the principal and management committee of their school. This was done, but there was no reply from the government once again. The aftermath of 13 May 1954 saw the formation of the Singapore Chinese Middle School Students Union (SCMSSU), and it was under the banner of SCMSSU that
16539-578: The police. Following the riot, students re-assembled in Chung Cheng High School and only dispersed in the afternoon on 14 May 1954. On 18 May 1954, a delegation of students (the 55-member Chinese Middle Schools Student Delegation) met the Chinese Chamber of Commerce (CCC), requesting the CCC's help to speak to the British government on their behalf. However, the only concrete result from this meeting
16688-613: The position of the Yang di-Pertuan Negara as the head of state, a prime minister and a wholly elected Legislative Assembly with 51 members. Subsequently, pursuant to the Malaysia Agreement of 1963, Singapore merged with the Federation of Malaysia , becoming one of its states and losing colonial status. Singapore was granted a new state constitution in the form of the Constitution of the State of Singapore 1963. The provisions relating to
16837-411: The postponement of national service for all students who are still schooling. According to Thum, once again drawing his opinions from Chinese sources, the process of appeal was made difficult for the students. For instance, their first petition was returned to them unopened because it was not submitted through "proper channels". With that, the students resubmitted their petition by registered mail however,
16986-428: The realm of constitutional law. Forms of soft law include non-binding instruments containing recommendations, government white papers , declarations, and informal rules like circulars or self-regulating codes of conduct . Unlike constitutional conventions , soft constitutional laws are authored by constitutional actors and reduced to written form, rather than derived from a custom or past practice. Such soft laws act as
17135-441: The result of communist agitation. Common hatred of exploitation, British rule and the declaration of Emergency paved the way for "13 May 1954", a resistance seen to be driven by overwhelming "leftist resentments against the British", with the rank and file on the ground taking initiative and moving without proper direction and control. In the view of scholars like Quee, Tan & Hong and Barr, & Trocki, 13 May 1954 represented
17284-457: The results of constitutional interpretation. This is because, during the process of constitutional interpretation, "the private philosophies and prejudices of individual judges will inevitably emerge". In 1980, when the Privy Council was still Singapore's final appellate court, it held in Ong Ah Chuan v. Public Prosecutor that where the fundamental liberties in the Constitution are concerned,
17433-526: The same as those associated with the House of Commons of the United Kingdom . In addition, Article 21(1) of the Constitution embodies the constitutionally recognised Westminster convention that the President generally acts on the advice of the Cabinet. Aside from adopted Westminster conventions, indigenous conventions have since developed or are developing to cater to local needs. During parliamentary debates in 1990 on
17582-477: The school children is very important and must not be overlooked. Especially in circumstances where the enemy is stronger than we are, the work of winning support from school children and organising them is more important than military activities. According to Lee (1996), the reason why the MCP started the mass movement from students can be attributed to two major reasons. First, the MCP recognised these Chinese students as
17731-432: The significance of certain figures that arose from United States government sources. The seeds of a communist discourse was being sown by American diplomats, pressuring the British government to take subversive actions against student and labour movements in post 1954 Singapore. Thus leading to the construction of events like the Hock Lee incident as a violent event instigated by communists. Kumar Ramakrishna 's latest work on
17880-412: The social and economic anxieties that were felt by both the students and the workers due to life in colonial society. Bilveer Singh stated that the Hock Lee riots revealed "the ability of the communists to mobilise other elements of the [Communist United Front], such as the students". Singh's reconstruction of the Hock Lee riots rely on the works of Bloodworth, Drysdale, and Lee. His analysis agrees with
18029-447: The social programmes that the government laid out, the most far-reaching and critical was education. The British envisioned setting up "national schools", prioritising English-medium education and undermining vernacular education. With that, Chinese schools were starved of funding, resulting in anger and resentments among the Chinese students and teachers. This led to a rise in anti-colonial sentiments. This growing anti-colonial sentiment
18178-475: The socialist club had a hand in organising "13 May 1954". This was in view that copies of the Fajar Publication (Issue 7 ) were found in the Chinese High Schools. With that, amidst the Chinese student's demonstration, the hostels of students from the socialist club were also raided by the police on 28 May 1954, and 8 members of the University socialist club were charged with sedition for articles printed in
18327-404: The students felt were unreasonable demands by the colonial government to prevent the set up of the student union. Newspaper reports of the government not providing help or compensation to victims of World War Two in Singapore also served as a reminder to students that they were being asked to fight for a government that does not have their interests at heart. Students were seen to be the allies of
18476-494: The students' path into university. The National Service Ordinance act also disrupted the education of Chinese students as the colonial government was unwilling to allow them to defer if they had to sit for examinations. This eventually led to the May 13 incident in 1954. In January 1955, the students' application to register the SCMSSU was rejected and subsequently met with many obstacles which
18625-440: The students, the attempt to recruit male youths for National Service took a back seat. The aftermath of 13 May 1954 resulted in the conviction of 7 students for obstructing the police during the demonstration, as well as further tightening of control over the students by the British. Different historical interpretations have been taken to the incidents occurring on and following 13 May 1954. The incidents have been characterised as
18774-407: The term constitution (with a lowercase c ) refers to the body of legal rules having constitutional effect in Singapore , while Constitution (with an uppercase C ) refers to the main statute containing constitutional rules. In Singapore, the sources of constitutional law may be grouped into two categories: those that are legally binding and those that are not. Legally binding sources include
18923-412: The text of the Constitution, judicial interpretations of the Constitution, and other statutes. Non-binding sources are influences on constitutional law such as soft law , constitutional conventions , and public international law . Singapore has a written constitution . The text of the Singapore Constitution which took effect from 9 August 1965 was a patchwork of provisions drawn from three statutes:
19072-409: The workers serving as a political force that could influence the decisions of the ruling elite. Loh et al. highlighted that many of the workers were ex-students and that the Chinese school students knew that the workers who were intertwined in labour negotiations was a reflection of their future. The anxieties of the students coupled with the students' sympathy to the workers resulted in their support for
19221-558: The workers. Therefore, the Hock Lee Bus Incident was not a moment of spontaneous communist action but was the effect of the intersections between opposing workers' and employers' sentiments towards the progressive establishment of trade unions which was one of the positive aspects of the Rendel Constitution. These activisms also arose as Singapore was going through a tough economic climate with goods prices increasing by almost 19 per cent; but wages only increased by 0.8 per cent between
19370-436: The written Constitution which underlie the Constitution and form the theoretical basis of constitutionalism, its goal being to achieve limited government . Examples of these principles include accommodative secularism , the rule of law , and the separation of powers . Similarly, the court's power of judicial review is not expressly mentioned, but has been read into the Constitution by necessary implication from Article 4 of
19519-695: Was The May 13 National Service Ordinance. And in 1955, there were three notable strikes namely the Hock Lee Bus workers' strike, the Singapore Traction Company strike and the Singapore Harbour Board strike. American officials were alarmed by both the rise of social unrest in Singapore and the Labour Front 's inability to control labour radicalism. It was estimated that 31,000 workers were involved in 129 official and sympathy strikes between March and June 1955. Some work has been done to study
19668-452: Was an event triggered by the flawed implementation of the system. Some overage students had been forced to miss examinations or leave school as a result of a call up. The lack of documents sent to these young men to explain the purpose of national service caused many to believe that they would be sent into the Malayan jungle to fight for the British. Students were also turned down time and again by
19817-425: Was an evident reaction to the operational challenges, poor administration and labour discontent that was evident in many of the bus companies. In 1970, RP Wilson was appointed to look into the reorganisation of public transportation in Singapore which resulted in the establishment of the government-led Singapore Transport Advisory Board in 1970, which sought to not only nationalise the bus companies but also to create
19966-401: Was crucial in supporting his victory in the 1959 elections. The 1959 election was the first full internal self-government granted by the British authority, and the People's Action Party led by Lee won 43 out of 51 seats in the legislative assembly, forming the government. However, this landslide victory would not have been possible without the support from the Chinese community, especially that of
20115-462: Was further fuelled by the larger anti-colonial sentiment that was also happening outside Singapore. Winning freedom for colonies in Africa and Asia played a part in instilling hope in the progressive left in Singapore, that independence may come one day. In 1948, the outbreak of communist insurrection in the Malayan jungles saw the declaration of emergency in Singapore. The declaration of emergency, which
20264-482: Was greatly depleted in jungle fighting during the earlier years of the State of Emergency between 1948 and 1960. The strategy focused on building relations and contacts with workers, peasants and students, emphasising on how plans and arrangements should be made in order to gain mass. According to Singh (2008), the first step of this strategy was to engage students through the exploitation of communal issues. Singh quotes an MCP directive as saying: The work of winning over
20413-421: Was having their school holidays being pushed forward by 2 weeks to deny students the opportunity to rally together. Having their school holidays pushed forward, this action prompted a second massive sit in by the students which took place on 23 May 1954 in Chung Cheng High School. However, due to the prevention of food supplies from reaching these students, the group dispersed. The third massive sit in took place in
20562-636: Was impeded as the British saw their strategic interests in Southeast Asia being challenged by peasant uprisings especially in Malaya. To maintain their control, the British tried to construct a narrative of communist insurgencies and militarism which could be potentially threatening to the security of the region. On the premise of containing communist activities, emergency regulations were implemented in 1948. These emergency regulations increased restriction on civil society meetings in Singapore. A turning point came as
20711-422: Was in no way "national" for it entailed "a colonial people to be trained to fight wars in the making of which they have no part – no choice of their foes or allies. Though we are not fit to rule ourselves, we are not unfit to die for other people's interests." Loh bases his opinion largely from the Fajar Publication itself. Anti-colonial sentiment was overwhelming, but the colonial authorities looked upon them as
20860-611: Was mandated in Singapore in 1993 by the enactment of section 9A of the Interpretation Act, which requires a court to prefer an interpretation that would "promote the purpose or object underlying the written law (whether that purpose or object is expressly stated in the written law or not) ... to an interpretation that would not promote that purpose or object". The Constitution of the Republic of Singapore Tribunal affirmed in Constitutional Reference No. 1 of 1995 that
21009-489: Was never applied consistently, and that "it appears that the 'four walls' doctrine has quietly fallen out of fashion at least in practice, as courts now regularly consider foreign cases which have only persuasive, not precedential value. ... It is fair to say that the development of Singapore public law is not accomplished in a cloister sealed off from transnational models, but through a thoughtful engagement with foreign cases." A purposive approach to statutory interpretation
21158-472: Was one of 275 strikes that took place in 1955. These activisms set the backdrop for the Hock Lee Bus workers' strike. There is evidence that the Hock Lee Bus workers' strike was not fully under the direction of the Malayan Communist Party (MCP) and that the workers were so passionate about their fight against colonial oppression and exploitation that even the MCP were not able to effectively restraint
21307-418: Was passed by Parliament on 22 December 1965, and made retrospective to 9 August 1965. Apart from making the fundamental liberties in the Malaysian Federal Constitution applicable in Singapore, the RSIA also received the legislative and executive powers over Singapore, which were relinquished by Malaysia through its Constitution and Malaysia (Singapore Amendment) Act 1965. The executive authority of Singapore
21456-441: Was published as part of the 1985 Revised Edition of The Statutes of the Republic of Singapore . The current reprint of the Constitution that is in force is the 1999 Reprint of the 1985 Revised Edition. Another source of legally binding constitutional law consists of the body of case law decided by the courts interpreting the Constitution, and laying down fundamental constitutional principles which are not expressly mentioned in
21605-509: Was published in the Government Gazette of 31 March 1980. Prior to the issuance of the 1980 Reprint, the Constitution had been criticised for being inaccessible due to its fragmented nature. The former Chief Minister of Singapore , David Marshall , commented that Singapore had "the untidiest and most confusing constitution that any country has started life with", while constitutional scholar R.H. Hickling acknowledged that "the problem of
21754-407: Was seen to be corrupt and inefficient and blamed for the poor working and economic conditions that the workers were subjected to. Strikes became more frequent as progression in the trade union movement was being challenged by the employers' refusal to recognise the unions and in its turn form splinter unions that would threaten the existing unionised workers. The Paya Lebar Bus Company labour protest
21903-409: Was shot one mile away from a hospital, but was paraded around for two and half-hours by the students to further arouse the crowd's emotion without sending him for medical treatment. The press, including the vernacular press and the English medium Straits Times, however later reported that it was revealed that the coroner stated in the lawyer's brief to Chong's mother that it was inconclusive as to whether
22052-437: Was to last for almost a decade, saw heightened security control. Singapore was turned into a police state; progressives and anti-colonial activists were rounded up; and political repression suspended all forms of left-wing politics in Singapore. While organised opposition to colonial rule was difficult, the period was nevertheless plagued with social discontent and stirrings of anti-colonial and nationalistic sentiments, in view of
22201-545: Was vested in the President and made exercisable by him or by the Cabinet , while the legislative powers of the Yang di-Pertuan Agong (Head of State of Malaysia) and the Parliament of Malaysia in respect of Singapore were vested in the President and the Parliament of Singapore. Furthermore, the RSIA empowered the President to "make such modifications in any written law as appear to him to be necessary or expedient in consequence of
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