IN THE HIGH COURT OF THE REPUBLIC OF SINGAPORE

 

Suit No. 2523 of 1996
Suit No. 181 of 1997
Suit No. 182 of 1997

 

Between

LEE KUAN YEW
(NRIC No. S0000003E)

... Plaintiff/s 

and

1. TANG LIANG HONG (NRIC No. S1096110F)
2. TEO SIEW HAR (NRIC No. S0531156Z)

...Defendant/s

 

 Suit No. 2524 of 1996
Suit No. 187 of 1997
 

Between 

GOH CHOK TONG
(NRIC No. S0046428G)

... Plaintiff/s

 and 

1. TANG LIANG HONG (NRIC No. S1096110F)
2. TEO SIEW HAR (NRIC No. S0531156Z)

...Defendant/s

Suit No. 172 of 1997 

Between

1. LEE KUAN YEW
(NRIC No. S0000003E)

2. LEE HSIEN LOONG
(NRIC No. S0016646D)

... Plaintiff/s
 

and
 

1. TANG LIANG HONG
(NRIC No. S1096110F)

2. TEO SIEW HAR
(NRIC No. S0531156Z)

...Defendant/s


Suit No. 1116 of 1996 


Between

1. LEE KUAN YEW
(NRIC No. S0000003E)

2. LEE HSIEN LOONG
(NRIC No. S0016646D)

... Plaintiff/s

 and 

1. TANG LIANG HONG
(NRIC No. S1096110F)

2. YAU LOP POON
(ID No. not known)

3. MING PAO MAGAZINE LIMITED
(Hong Kong RC No. 175907)

4. DAI NIPPON PRINTING COMPANY
(Hong Kong RC No. 10077)

5. TEO SIEW HAR
(NRIC No. S0531156Z)

...Defendant/s
 

Suit No. 70 of 1997

Between
 

LEE HSIEN LOONG
(NRIC No. S0016646D)


... Plaintiff/s
 

and

1. TANG LIANG HONG
(NRIC No. S1096110F)

2. TEO SIEW HAR
(NRIC No. S0531156Z)

...Defendant/s

Suit No.76 of 1997

Between

TONY TAN KENG YAM
(NRIC No. S1136758E)


... Plaintiff/s
 

and

1. TANG LIANG HONG
(NRIC No. S1096110F)

2. TEO SIEW HAR
(NRIC No. S0531156Z)


...Defendant/s
 


Suit No. 82 OF 1997

Between
 

LEE YOCK SUAN
(NRIC No. S0406096B)


... Plaintiff/s 

and

1. TANG LIANG HONG
(NRIC No. S1096110F)

2. TEO SIEW HAR
(NRIC No. S0531156Z)

...Defendant/s

Suit No. 2525 of 1996
Suit No. 188 of 1997
 

Between
 

1. TEO CHEE HEAN
(NRIC No. S0158131G)

2. CH’NG JIT KOON
(NRIC No. S0816644G)

3. OW CHIN HOCK
(NRIC No. S0036442H)

4. CHIN HARN TONG
(NRIC No. S0001050B)

5. KER SIN TZE
(NRIC No. S0398064B)

6. SENG HAN THONG
(NRIC No. S0098408F)

... Plaintiff/s

 

and

 

1. TANG LIANG HONG
(NRIC No. S1096110F)

2. TEO SIEW HAR
(NRIC No. S0531156Z)

...Defendant/s

 

A F F I D A V I T

 

I, TANG LIANG HONG (NRIC No. S1096110F), of 75 Hua Guan Avenue, Singapore hereby affirm and says as follows : 

  • Save where otherwise indicated, the facts and matters deposed to herein are based upon matters which are within my personal knowledge, and are true to the best of my knowledge, information and belief. Where the facts and matters deposed to herein are based upon information which has been provided to me by third parties, I hereby affirm that I verily believe such information to be true and accurate.
  • Mr Lee Kuan Yew, a plaintiff to several of the several suits presently instituted against me ("SM Lee"), was one of the principal partners of Messrs. Lee & Lee ("LL") until he joined politics and entered the Singapore government. After SM Lee left LL, his wife, Mdm Kwa Geok Choo ("Madam Kwa"), and his brother, Dennis Lee Kim Yew ("Dennis Lee") remained the principal partners of LL.
     
  • Justice Lai Kew Chai worked for LL for many years, initially, as a legal assistant and later as a partner, before he became a high court judge.
     
  • LL had advised SM Lee and other members of his family on many matters in the past. As a member of LL, Justice Lai had a close working relationship with SM Lee and other members of his family, and had acted in a variety of matters involving SM Lee and other members of his family.
  • It is widely known in the Singapore society that Justice Lai was and still is a close friend of the Lee family
     
  • There are currently 13 law suits instituted against me, 3 of which is brought by SM Lee solely, 2 by his son, Lee Hsien Loong ("DPM Lee"), and a further 2 by SM Lee and DPM Lee jointly.
     
  • Sometime between April and early May of 1995, a Singapore publicly listed property developer known as Hotel Property Limited ("HPL") of which Dr. Lee Suan Yew, (a younger brother of SM Lee), was a director, offered units at its property project known as Nassim Jade to "close business associates" for sale before its official launch for sale to the public. During that period of time, there was a boom in the Singapore property market and it was therefore a privilege to be invited to pre-launch sale for purchase of property. For obvious reasons, such privileges are usually reserved to a selected few. The invitees to such pre-launch sales were known as "Early Bird Buyers" in Singapore.
     
  • When the pre-launch sale offer was made by HPL in respect of Nassim Jade, Madam Kwa, DPM Lee Hsien Loong , and other members of SM Lee’s family were among the "Early Bird Buyers". Justice Lai was also one of the Nassim Jade "Early Bird Buyers".
     
  • I enclose herewith a copy of each of the two (2) schedules made out from caveats lodged at the Land Registry and marked Exihibit "TLH-1" and Exhibit "TLH-2" respectively. I refer to the said exhibits, and respectfully draw this Court’s attention to the fact that Justice Lai, Freddy Lee Thiam Yew (SM Lee’s younger brother) and one Shi Ka Yee are the three parties who paid the lowest price per square foot for their Nassim Jade units. In addition, Justice Lai signed the contract of sale and purchase in respect of his Nassim Jade unit on the same day as SM Lee and DPM Lee signed theirs, namely, 16 May 1995. I submit to the Court that the matters stated in this and the preceding sub-paragraph are further evidence of the close ties between Justice Lai and the Lee family.
     
  • The purchases of Nassim Jade units by SM Lee, DPM Lee and members of their family subsequently became known publicly, and was widely criticised, in Singapore. Upon the direction of Prime Minister, Goh Chok Tong, these purchases were investigated by Finance Minister, Richard Hu, and the Deputy Director of the Monetary Authority of Singapore, Koh Beng Seng.
     
  • At that time, I was interviewed by a reporter from Asian Weekly Magazine (Yazhou Zhoukan) on this issue, and I commented as follows:
    1. "Why wasn’t this matter handed over to the professional body like Commercial Affairs Department or Corrupt Practice Investigation Bureau? They are government departments not only rich in experience, but are also well-known for being "iron-faced with selfishness" [a Chinese phrase meaning firm and impartial]. They would be more detached and their reports would have been more convincing to the people. Koh Beng Seng and Finance Minister Richard Hu are after all not experts in this field."
       
    2. SM Lee and DPM Lee took offence at my comments and sued me for defamation in Suit No. 1116 of 1996. I enclose herewith a copy of my amended defence and marked "TLH-3" to which amended defence my counsel shall refer at the hearing of this application. I submit that, one of the issues which will be raised at the trial of this case will be the large discounts given to persons holding high positions in government or other public authorities; as well as, whether HPL, as a publicly-listed company had discharged its duty to shareholders to obtain the best price for its property development in view of the discounts given to "Early Birds Buyers".
  • I submit that by reason of the discount which he was given, his position as a High Court judge and his relationship with SM Lee and other members of SM Lee’s family, Justice Lai’s purchase of his Nassim Jade unit will be one of the subject-matters raised for deliberation at trial, and evidence concerning his purchase may be adduced.
     
  • By reason of the same, Justice Lai cannot be seen to be impartial, and cannot be said to be a fit and proper judge to preside over Suit No. 1116 of 1996. Yet, Justice Lai did not declare this, and has made several orders in respect of Suit No. 1116, including joining my wife as a co-defendant, granting a Mareva Injunction and appointing a receiver over my and my wife’s assets. These orders have caused great hardship for both my wife and I.
     
  • Justice Lai is also presently presiding over all the other 12 law suits instituted against me.
  • The institution of the 13 law suits against me, and the conduct of these proceedings to date, has been oppressive.
     
  • In his judgment which granted the Mareva Injunction, Justice Lai failed to refer to my speech of August 1994, which I submit is the most cogent evidence that all the accusations made by the Plaintiffs against me cannot be substantiated, and are therefore false. In the premises, it is therefore not defamatory for me to described the Plaintiffs as having "lied". Even if the Court was not minded to determine this issue before the trial, at the very least, it cannot be said that the Plaintiffs have satisfied the requirement that they had a good arguable case nor can they show that there are serious questions to be tried, such as is required for the granting of a Mareva Injunction.
     
  • There is no evidence to say that I have absconded or that I have taken steps to remove my assets out of the jurisdiction. My family and friends are in Singapore. I have lived in Singapore all my life, and my life is there. I am staying away from Singapore for the time being simply because the PAP government has made it impossible for me to live in Singapore at the moment. The allegations made by the Plaintiffs that I am absconding are groundless - For example, the Plaintiffs relied on the fact that many boxes were being moved from my office premises, but in fact all those boxes contained closed files, and there was no space at the office of Mr JB Jeyaretnam to store them. If I had intended to hide these boxes, I would not have moved them to my home. In view of the facts, there were no grounds for Justice Lai to grant a Mareva Injunction.
     
  • Further, in late January 1997, when several of my Defences to the actions herein were due to be filed, I was away from Singapore, and needed more time to settle my Defences as the issues raised in the Statements of Claims were lengthy and complex, and there were several Defences due to be filed at the same time. My request to the Plaintiffs’ solicitors and my application to the Court for extension of time were both rejected. From experience, this is most unusual in legal practice, particularly as it was a first request for extension of time, and the issues invloved were lengthy and complex. By the time the drafts of the said Defences were finalised, they could not be delivered by courier in time for filing in accordance with the time-limits. I only managed to file the said Defences within the stipulated time in accordance with the rules, because, after having waited long hours at the Heathrow airport, and approaching many other passengers in vain, I managed a passenger at the London Heathrow airport who was willing to carry my Defences back to Singapore for me. Yet, SM Lee said that my application for an extension of time was merely a tactic to delay proceedings to enable me to remove my assets from Singapore. This is absurd.
     
  • The Plaintiffs have defamed me, and yet they are suing me for defamation. Instead of proving these cases in court, they are trying to obtain judgment against me without going to trial, namely, by freezing my and my wife’s assets, so that I lose all my ability to resist their bullying in the courts.
     
  • By reason of the matters stated in this affidavit, I hereby apply for the discharge of Justice Lai from all the actions herein, and for all the orders which he has made in respect all the actions herein to be declared null and void.
     
  • I reserve my rights to answer all the other allegations raised in the many affidavits filed by the Plaintiffs in support of the Mareva Injunctions and the appointment of the Receiver.
  •  

     

    AFFIRMED at ( )
    (Hong Kong )
    (on this 1st day of March, 1997 )

     

    BEFORE ME,

    Click here to view HPL Properties Purchasers List

    IN THE HIGH COURT OF THE REPUBLIC OF SINGAPORE

    Suit No. 2523 of 1996
    Suit No. 181 of 1997
    Suit No. 182 of 1997
     

    Between

    LEE KUAN YEW
    (NRIC No. S0000003E)

    ... Plaintiff/s

    and

    1. TANG LIANG HONG
    (NRIC No. S1096110F)

    2. TEO SIEW HAR
    (NRIC No. S0531156Z)

    ...Defendant/s

    Suit No. 2524 of 1996
    Suit No. 187 of 1997
     

    Between
     

    GOH CHOK TONG
    (NRIC No. S0046428G)

    ... Plaintiff/s
     

    and

    1. TANG LIANG HONG
    (NRIC No. S1096110F)

    2. TEO SIEW HAR
    (NRIC No. S0531156Z)

    ...Defendant/s

     

    Suit No. 172 of 1997
     

    Between
     

    1. LEE KUAN YEW
    (NRIC No. S0000003E)

    2. LEE HSIEN LOONG
    (NRIC No. S0016646D)

    ... Plaintiff/s

    and

     

    1. TANG LIANG HONG
    (NRIC No. S1096110F)

    2. TEO SIEW HAR
    (NRIC No. S0531156Z)

    ...Defendant/s

     

    Suit No. 1116 of 1996

     

    Between

     

    1. LEE KUAN YEW
    (NRIC No. S0000003E)

    2. LEE HSIEN LOONG
    (NRIC No. S0016646D)

    ... Plaintiff/s

    and

     

    1. TANG LIANG HONG
    (NRIC No. S1096110F)

    2. YAU LOP POON
    (ID No. not known)

    3. MING PAO MAGAZINE LIMITED
    (Hong Kong RC No. 175907)

    4. DAI NIPPON PRINTING COMPANY
    (Hong Kong RC No. 10077)

    5. TEO SIEW HAR (NRIC No. S0531156Z)

    ...Defendant/s

     


    Suit No. 70 of 1997

     
    Between
     

    LEE HSIEN LOONG
    (NRIC No. S0016646D)

    ... Plaintiff/s
     

    and

     

    1. TANG LIANG HONG
    (NRIC No. S1096110F)

    2. TEO SIEW HAR
    (NRIC No. S0531156Z)

    ...Defendant/s

     

    Suit No.76 of 1997

    Between
     

    TONY TAN KENG YAM
    (NRIC No. S1136758E)

    ... Plaintiff/

    and
     

    1. TANG LIANG HONG
    (NRIC No. S1096110F)

    2. TEO SIEW HAR
    (NRIC No. S0531156Z)

    ...Defendant/s 

     

     

    Suit No. 82 OF 1997

    Between

     

    LEE YOCK SUAN
    (NRIC No. S0406096B)

    ... Plaintiff/s

    and
     

    1. TANG LIANG HONG
    (NRIC No. S1096110F)

    2. TEO SIEW HAR
    (NRIC No. S0531156Z)

    ...Defendant/s

     

    Suit No. 2525 of 1996
    Suit No. 188 of 1997
     

    Between
     

    1. TEO CHEE HEAN
    (NRIC No. S0158131G)

    2. CH’NG JIT KOON
    (NRIC No. S0816644G)

    3. OW CHIN HOCK
    (NRIC No. S0036442H)

    4. CHIN HARN TONG
    (NRIC No. S0001050B)

    5. KER SIN TZE
    (NRIC No. S0398064B)

    6. SENG HAN THONG
    (NRIC No. S0098408F)

    ... Plaintiff/s
     

    and

    1. TANG LIANG HONG
    (NRIC No. S1096110F)

    2. TEO SIEW HAR
    (NRIC No. S0531156Z)

    ...Defendant/s

    _________________________________________

    AFFIDAVIT
    __________________________________________