Re Fong Thin Choo
Re Fong Thin Choo is an administrative law case decided in 1991 by the High Court of Singapore concerning the legality of a demand by the Director-General of Customs and Excise ("DG") that the applicant's company pay S$130,241.30 in customs duty as it had not exported certain goods. The case was presided over by Justice Chan Sek Keong. The Court decided that the DG had failed to take into account relevant evidence adduced by the applicant's company which could have been capable of rebutting the prima facie evidence of non-export, and had thus made an insufficient inquiry before arriving at his decision. Since the DG's demand had been based on an incorrect basis of fact and thus had been made contrary to law, the Court granted the applicant an order of prohibition that barred the DG from deducting the sum from certain bankers' guarantees that the applicant's company had lodged with Customs as security. The case appears to have introduced error of material fact into Singapore case law as a ground of judicial review.