29 Jan 08
29 January 2008
The Licensing Officer
Police Licensing Division
Police Cantonment Complex
391 New Bridge Road
Blk D #02-701
Re: Application for Police Permit For Protest Rally Outside Parliament House
We act for Dr Chee Soon Juan of the Singapore Democratic Party in the above matter.
Our client has made an application for a permit to stage a protest rally outside the Parliament House on 15 March 2008 on World Consumer Rights Day. We note that our client’s application is still under consideration.
Our client records his dismay that in the past your refusal to issue a permit usually reaches our client at the 11th hour after the public has been informed of the rally and logistical arrangements have been made.
This not only creates much inconvenience to our client and fellow citizens but is an unusual departure from the much celebrated tenet of efficiency of our civil service. Such a late response also violates the Public Entertainment and Meetings Act (“Act”).
In this regard, we would like to draw your attention to Section 13 (2) of the Act that states “the Licensing Officer shall, if so requested by the applicant or the licensee, as the case may be, furnish the applicant or the licensee within 7 days of being so required with the grounds of such refusal in writing.”
Further reference is also made to section 13 (3) which states that “any applicant or licensee who is aggrieved by the refusal of the Licensing Officer may, within 14 days of the furnishing to him of the grounds of the refusal, appeal in writing to the Minister whose decision shall be final”.
It is clear from the aforesaid sections 13(2) and (3) that any decisions to refuse permit ought to be made known within the stipulated time, at least 21 before the event for which the permit is being sought or preferably much earlier as this would enable our client to lodge an appeal with the Minister.
It would make nonsense of the aforesaid provisions if an appeal is to be made or a decision by the Minister on any appeal is made known to our client after the scheduled date of the protest rally.
If your decision is made known to our client too late, the aforesaid provisions under the Act are of no effect. We would appreciate if you could let us know the status of our client’s application within the next seven(7) days from the date hereof.
Please note that the Minister’s decision, albeit final, is still subject to judicial review if his decision violates Article 12 of the Constitution which gives the right to equal treatment and if there is any discrimination against our client, our client’s rights are hereby expressly reserved.
M Ravi & Co.