[2026] SGDC 189

This was a particularly reprehensible child abuse case involving a preschool principal, JHJ (“the Offender”), aged 40, who physically abused a young child (“the Victim”) in the childcare centre under her charge. As the most senior childcare professional at the centre, the Offender was the ultimate custodian of the children’s welfare and safety while they were at the centre. However, she cast aside every professional and moral obligation her position demanded of her, and subjected the defenceless child to a sustained, unprovoked physical assault lasting over four minutes. That the Victim remained passive throughout only deepened the gravity of what occurred: there was no provocation, no struggle, and no justification. There was only a child, and an adult in a position of trust who chose to abuse that trust.

Introduction

On 22 April 2026, the Offender pleaded guilty to a single charge of ill-treatment of a child (DAC-900464-2026) which reads as follows:

You […] are charged that you, on 21 November 2024, at about 10.53am, at [address redacted], having care of a child, one [name redacted] (male, then 4-years-old, DOB: [redacted]) (the “Victim”), did ill-treat the Victim, by unreasonably doing an act which caused the said Victim unnecessary physical pain, to wit, by:

a. hitting the left side of the victim’s head;

b. grabbing the victim’s left arm and pulling the victim up about 6 times;

c. holding onto the chin of the victim;

d. pushing the victim back down into his seat;

e. hitting the right side of the victim’s head;

f. hitting the victim’s right arm;

g. using the plastic cover to hit the top of the victim’s head; and

h. pushing the right side of the victim’s head two times,

and you have thereby committed an offence under Section 6(1) of the Children and Young Persons Act 1993 (“CYPA”) punishable under Section 6(6)(b) of the CYPA.

The Prosecution sought a custodial sentence of six to eight months while the Defence urged the Court to impose a high fine, or in the alternative, an imprisonment term not exceeding three months. Neither the Prosecution’s nor the Defence’s sentencing position adequately reflected the Offender’s culpability, and I found it necessary to depart from both. A sentence of 10 months’ imprisonment was imposed, backdated to the date of the Offender’s arrest, viz, 21 November 2024 (excluding the period she was on bail, viz, 22 November to 23 April 2026). The Offender is currently serving her sentence.

Facts

The salient portions of the Statement of Facts (with the offending acts in bold) which the Offender admitted to without qualification were as follows:

(a) The Offender was the principal of [name redacted] (the “Childcare Centre”) and the Victim was one of her students. On 21 November 2024, at about 10.53am, the Victim attempted to pull down a box of toys (“the Box”) from the shelves next to him whilst seated. A teacher instructed him to stand up to retrieve the Box but he refused.

(b) The Offender witnessed this and intervened. She first hit the left side of the Victim’s head before grabbing his left arm and pulling him up. Upon noticing that the Victim had urinated in his pants, the Offender grew even more frustrated and repeated the same action about five more times. She then held onto the Victim’s chin before pushing him back down into his seat.

(c) The Victim eventually stood up and moved away from his seat. Despite this, the Offender hit the right side of the Victim’s head. When the Victim refused to head to the toilet, the Offender then told him that he could sit on the chair again and the Victim did so.

(d) The Offender then directed the other students to help pick up the toys that fell out of the Box. As she herself bent over to pick up the toys, the Offender hit the Victim’s right arm. She then used the plastic cover of the Box to hit the top of the Victim’s head. After the toys were placed into the Box, the Offender pushed the right side of the Victim’s head twice.

(e) The Offender’s acts of abuse lasted for over four minutes and were captured on the closed-circuit television (“CCTV”). The relevant portions of the footage were played in court.

(f) One of the teachers later informed the Offender that there were scratches on the Victim’s left arm. When the Victim’s father went to collect the Victim, the Offender told him about the scratches but claimed that they were caused when she pulled the Victim away to prevent the Box from falling onto him. Upon returning home, the Victim’s father noticed that the scratches were significant. He spoke to the Offender over the phone and asked how many times she had pulled the Victim to which the Offender replied that she had only done it once.

(g) The Victim’s father brought the Victim to the hospital later that day and the Victim was found to have sustained six superficial linear scratch marks of varying lengths between one and four centimetres over the medial aspect of his left arm.

Antecedents

The Offender was a first offender.

Parties’ submissions

Prosecution’s address on sentence

The Prosecution sought a custodial term of six to eight months and submitted that the main sentencing considerations were deterrence and retribution. It highlighted the 2019 amendments to the CYPA which doubled the maximum prescribed fine and imprisonment term for non-fatal child abuse cases under the statute. Citing Minister for Home Affairs Mr K Shanmugam’s parliamentary speech at the Second Reading of the Criminal Law Reform Bill (Singapore Parliamentary Debates, Official Report (6 May 2019) vol 94), the Prosecution explained that Parliament’s intent behind the amendment was to “better protect vulnerable victims […] and reflect our commitment to protect such persons”. Statistics were also provided showing a significant increase in the number of child mismanagement cases in preschools investigated by the Early Childhood Development Agency (“ECDA”), from 169 cases in 2023 to 227 cases in 2024.

To support its sentencing position, the Prosecution pointed out the observation of the Court of Appeal (“CA”) in PP v BDB [2018] 1 SLR 127 (“BDB”) (at [86]) that “the courts invariably imposed a term of imprisonment of at least six months” [emphasis in original] for non-fatal child abuse cases. However, it emphasised that this observation was made before the 2019 amendments to the CYPA and there should therefore be an increase in the sentences meted out for post-amendment child abuse cases.

In submitting for a sentence of nine to 12 months’ imprisonment on a claim trial basis, the Prosecution raised the following sentencing factors which were set out in BDB (at [85]) for the Court’s consideration:

(a) Extent of deliberation: While not premeditated, the offending acts were clearly deliberate.

(b) Manner and duration of attack: The Offender committed eight discrete acts of violence towards the Victim for a sustained period of over four minutes.

(c) The Victim’s vulnerability: The Victim was merely four years old and there was a great physical disparity between him and the Offender.

(d) Use of a weapon: The Offender used a plastic cover to hit the Victim’s head.

(e) Injury suffered by the Victim: The Victim sustained six superficial linear scratch marks of varying length between one and four centimetres over the medial aspect of his left arm.

As the Offender pleaded guilty at an early stage, the Prosecution did not object to a 30% reduction in sentence, resulting in an imprisonment term of six to eight months.

Additionally, the Prosecution cited the following precedents in support of its sentencing position:

1. PP v Franklie Tan Guang Wei [2016] SGDC 263 (“Franklie”)

Offender: 25 years old / boyfriend of victim’s mother / untraced

The offender pleaded guilty to four proceeded charges, one under s 325 of the Penal Code (Cap 224, 2008 Rev Ed) (“the Penal Code”) and three under s 5(1) punishable under s 5(5)(b) of the Children and Young Persons Act (Cap 38, 2001 Rev Ed) (“the 2001 CYPA”).

For one of the 2001 CYPA charges, the offender was upset at the victim for crying and slapped him, causing him to sustain a bruise near his ear and marks on his face. He was sentenced to nine months’ imprisonment for this charge and a total sentence of six years and six months’ imprisonment with six strokes of the cane.

Victim: 1 year old

2. PP v Ma Yujie [2025] SGDC 167 (“Ma Yujie”)

Offender: 29 years old / victim’s preschool teacher / untraced

The offender pleaded guilty to a single charge under s 6(1) punishable under s 6(6)(b) of the CYPA for failing to take reasonable steps to protect the victim from the risk of ill-treatment by another teacher. She watched the latter abuse the victim for over 10 minutes by trapping her under a table against a wall, repeatedly shoving the table against the victim’s torso, and hitting the victim’s head twice with a plastic divider. The victim suffered bruises on the face.

The offender was sentenced to 14 days’ imprisonment.

Victim: 2 years old

3. PP v Alamelu D/O Paramaguru [2025] SGDC 217 (“Alamelu”)

Offender: 57 years old / victim’s preschool teacher / untraced

The offender pleaded guilty to a single charge under s 6(1) punishable under s 6(6)(b) of the CYPA for kicking the victim once on the shin. The victim sustained a one-by-one centimetre haematoma and was issued two days of medical leave.

A sentence of four days’ imprisonment was imposed.

Victim: 4 years old

Defence’s mitigation plea

The Defence submitted for a high fine or, in the alternative, an imprisonment term of not more than three months, citing the following personal factors in support:

(a) The Offender had worked in the childcare industry for about 18 years and was a principal at various schools for almost a decade without any similar incident. Within a day of the offence, the Offender voluntarily resigned as she felt that she was no longer fit for the job.

(b) There were multiple unfortunate events in the Offender’s life prior to the offence: (i) her mother passed away about 10 months earlier; (ii) she was divorced about four months prior; (iii) her brother got divorced about one month after her divorce; and (iv) she obtained a personal protection order against her alcoholic and abusive ex-husband in the preceding year.

(c) The Offender was emotionally affected and depressed after her mother’s passing and was hospitalised several times that year. On the day of the offence, the Offender was supposed to be on medical leave but insisted on working to assist the students with their graduation ceremony rehearsals.

(d) She had volunteered with a couple of social institutions, viz, NuLife Care & Counselling Services and Singapore Aftercare Association.

Further, while the Defence acknowledged the primacy of deterrence in child abuse cases, it urged the Court to consider the full facts of the case, including the following:

(a) The offence occurred over a four-minute period and was not premeditated.

(b) The Offender lost her temper as the Victim defied her repeated instructions for him to stand up and continued to sit in his soiled clothes.

(c) The Victim did not cry or scream when the offending acts were committed against him.

(d) The only item that the Offender used to hit the Victim was a plastic cover.

(e) After the Victim’s father returned home with the Victim, he spoke to the Offender over the phone and said that the Victim had identified another teacher as the culprit. The Offender confirmed that she was the one who had committed the offence and offered to let the Victim’s parents view the CCTV footage at the school.

(f) The only injuries to the Victim were six superficial scratch marks and he did not require further medical attention.

(g) The Offender’s intention was to get the Victim away from the soiled chair so that she could resume the rehearsal.

Decision on sentence

Having considered the written and oral submissions of both the Prosecution and the Defence, I declined to adopt either of their sentencing positions as I was of the view that they were inadequate to reflect the gravity of the offence and the Offender’s criminality. In my opinion, a sentence of 10 months’ imprisonment was necessary to serve the interests of justice.

Prescribed punishment

An offence under s 6(1) punishable under s 6(6)(b) of the CYPA carries a fine not exceeding $8,000 or imprisonment for a term not exceeding eight years or both. As highlighted by the Prosecution, the penalty for this offence was doubled in 2019. The intent behind the enhancement is evident from the following portions of Minister for Home Affairs Mr K Shanmugam’s speech (Singapore Parliamentary Debates, Official Report (6 May 2019) vol 94):

[…] I intend to set out the Government’s position on two major areas of the law which we are amending. One, better protection of vulnerable victims; and second, dealing with sexual offences. We are setting out new offences and enhancing penalties where minors are involved. Some additional conduct of a sexual nature will be specifically criminalised.

First, protection for vulnerable victims. We want to provide stronger protection for those who cannot protect themselves. First, we will enhance maximum punishment for offences committed against such victims. Second, we will introduce new offences where such victims are abused. The first category of vulnerable victims are children below 14 years old; second, vulnerable persons due to mental or physical disabilities; and third, domestic workers.

[…]

Mr Speaker, Sir, these enhanced penalties and new offences created will help to better protect vulnerable victims, victims of sexual crimes and reflect our commitment to protect such persons. The amendments we are making today strengthen our laws. They will help ensure that Singapore continues to be a safe home for our people, particularly women, children, and vulnerable persons.

[emphasis added]

It is amply clear that Parliament intended to strengthen the protection of vulnerable persons such as the Victim through the imposition of harsher sentences against their offenders.

Sentencing principles

Deterrence and retribution are the dominant sentencing considerations in child abuse cases (BDB at [85]).

Children, especially young ones such as the Victim, are among the most vulnerable members of our society. Their vulnerability stems from their inability to defend themselves or report the abuse committed against them. This may embolden perpetrators and allow the abuse to go undetected and unpunished. A strong signal must thus be sent to potential offenders that gratuitous violence against children will not be tolerated. As the CA observed in BDB (at [36]):

By maintaining an uncompromising stance against offenders who abuse vulnerable victims, several objectives may be served. First, this helps to deter other like-minded members of the public, as was observed in PP v Law Aik Meng [2007] 2 SLR(R) 814 (“Law Aik Meng”) at [24(b)] and AFR at [12] and [30]. Second, by denouncing such conduct through the imposition of stiff sentences, we give expression to public outrage at the fact that the offenders in question have taken advantage of their victims’ vulnerability: see Kow Keng Siong, Sentencing Principles in Singapore (Academy Publishing, 2009) (“Sentencing Principles in Singapore”) at para 16.060. Third, the sentencing consideration of retribution is engaged in cases where serious violence is inflicted on a vulnerable victim. Fourth, imposing a severe sentence in such cases helps to ensure that the punishment is proportionate to the offender’s culpability: see AFR at [32].

[emphasis added]

It bears noting that the Offender was not a mere stranger to the Victim but was in a caregiver role vis-à-vis the Victim. The need for a deterrent sentence is greater in such cases (PP v AFR [2011] 3 SLR 833 (“AFR”) at [12]):

In view of the disturbing brutal violence inflicted on the Child (as described at [3]–[5] above and [23]–[26] below) and the disconcerting increase in the incidence of domestic violence cases involving young children, this court, in coming to its decision on the present appeal, felt compelled to send a clear signal to all parents and caregivers (ie, those in a position of authority over and/or having a duty of care in relation to young children) that any unwarranted infliction of violence on young children would not be tolerated and would be met with the full force of the law. No parent or caregiver has licence to inflict violence with impunity on any young children under his charge. … a parent or caregiver who breaches the trust and confidence reposed in him by abusing his child or ward will face the most severe condemnation of the law.

[emphasis added]

As the Prosecution highlighted, there has been a significant rise in reports of child mismanagement cases (actions that compromise a child’s safety or well-being) in preschools, from 169 cases in 2023 to 227 cases in 2024. While these figures included reports of non-criminal allegations such as intentional neglect, the approximately 34% increase was nonetheless disconcerting.

Appropriate sentence

In deciding on the appropriate sentence, I was guided by the CA’s observation (at [86]) in BDB that for “non-fatal child abuse cases, the courts invariably imposed a term of imprisonment of at least six months for offences prosecuted under s 5 of the CYPA [predecessor of s 6 of the CYPA]” [emphasis in original]. Notably, BDB was decided before the prescribed punishment for such offences was doubled. Seen in this light, the Defence’s sentencing position of a high fine or an imprisonment term not exceeding three months was patently untenable. This was so even after accounting for the applicable mitigating factors, as will be elaborated upon below.

The court in BDB had also set out (at [62], [71] and [85]) the following non-exhaustive aggravating and mitigating factors which are relevant for child abuse offences prosecuted under s 5 of the CYPA (predecessor of s 6 of the CYPA):

Aggravating factors

(a) the extent of deliberation or premeditation;

(b) the manner and duration of the attack;

(c) the victim’s vulnerability;

(d) the use of any weapon;

(e) whether the attack was undertaken by a group;

(f) any relevant antecedents on the offender’s part; and

(g) any prior intervention by the authorities.

Mitigating factors

(a) the offender’s mental condition;

(b) the offender’s genuine remorse; and

(c) the offender’s personal financial or social problems.

Several of the above aggravating factors are present in this case as identified by the Prosecution (see [8] above):

(a) The offence was committed in a deliberate manner. In this regard, the court in BDB had noted (at [86]) that “offenders who wilfully inflict injury on a child […] may be regarded as being more culpable than offenders who act unreasonably in doing so, and should therefore receive harsher sentences” [emphasis in original].

(b) The offence involved multiple forms of violence and lasted for more than four minutes.

(c) The Victim was merely four years old and there was a huge physical disparity between him and the Offender. As held in BDB (at [34]), “the more vulnerable the victim, the more culpable the offender”.

(d) The Offender had used a weapon, viz, a plastic cover, to strike the Victim’s head. While this was not a particularly dangerous item, consideration should be given to the fact that the Offender had not only used her bare hands to attack the Victim but had employed an object to strike him. In addition, as can be seen from the CCTV footage, the Offender had used a significant amount of force when hitting the Victim’s head with the cover.

While the Prosecution submitted that the extent of the Victim’s injuries was an aggravating factor, I did not agree. The six superficial linear scratch marks, ranging between one and four centimetres on the left arm, were relatively minor in nature. Based on the medical report dated 17 October 2025 tendered by the Prosecution, the Victim was discharged well with antibiotic cream and analgesia and did not require further medical attention. I therefore did not treat the injuries as an aggravating factor, though I note for completeness that the marks were multiple and clearly visible (SOF at ANNEX C).

Apart from those flagged by the Prosecution, the following additional aggravating factors were also present in this case:

(a) The Offender had targeted a vulnerable part of the Victim’s body, viz, his head, not once or twice but five times. In particular, she had hit his head twice and pushed it twice with her hand and hit his head with the plastic cover once.

(b) The attack occurred in full view of the other young and impressionable children at the Childcare Centre. As seen from the CCTV footage, there were around 25 students in the room where the offence occurred.

(c) The Offender had abused the relationship of trust and authority she had over the Victim. As the principal of the Childcare Centre, the Offender owed a duty of care to all the children who attended the institution to keep them safe. She had utterly breached her duty by committing the offence against the Victim. The fact that she did so openly in the presence of the other teachers underscored the need for the sentence to reflect the seniority of the Offender’s position and the authority she commanded at the centre.

(d) Instead of showing contrition and concern for the Victim after her sustained assault on him, the Offender continued to berate the Victim and pointed her finger at him multiple times as seen in the CCTV footage. Her lack of remorse in the immediate aftermath of the incident was also evident from how she lied to the Victim’s father that the scratches on the Victim were caused when she pulled the Victim to prevent a box from falling onto him. This was plainly untrue. The Offender’s first act was to hit the Victim’s head. If she had genuinely wanted to prevent the box from falling onto the Victim, she should have held onto the box instead of inflicting harm on the Victim. In fact, her smack on the Victim's head caused him to lose his grip on the box, resulting in the contents of the box scattering all over, including onto the Victim. The Offender had also lied to the Victim’s father that she had only pulled the Victim once.

Apart from the Offender’s early plea of guilt and lack of criminal antecedents, I did not think there was any other mitigating factor present. The Defence had raised the Offender’s various life stressors in the year prior to the offence, viz, her mother’s death in January 2024, her divorce in July 2024, her brother’s divorce in August 2024, and her obtaining a personal protection order against her ex-husband in November 2023. However, these did not in any way excuse her behaviour or justify her directing her frustrations at an innocent and defenceless child.

As observed by the CA in BDB (at [75]), “frustrations faced by a parent or caregiver due to his or her difficult personal circumstances can never justify or excuse the abuse of [young and other vulnerable victims]” [emphasis in original]. The CA also referred to the following passage in PP v AFR, where the court emphasised (at [12]):

… Any parent or caregiver who [inflicts violence on young children under his charge] will not be allowed to mitigate his culpability on the ground of financial or social problems, nor will he be allowed (for mitigation purposes) to exclaim with regret that he did not mean to inflict violence on the victim in question, whom he professes to love. …

[emphasis in original]

In light of the above, had the Offender claimed trial, I would have imposed a sentence of around 14 months’ imprisonment upon conviction. Given that the Offender had indicated her intention to plead guilty at Stage 1 of the Sentencing Advisory Panel’s Guidelines on Reduction in Sentences for Guilty Pleas, I accorded her the maximum 30% reduction in sentence, resulting in a sentence of 10 months’ imprisonment.

For completeness, I considered the sentencing precedents cited by the Prosecution (see [10] above) but did not think they were of much assistance. Franklie predated the amendments to the CYPA, and the offender there faced multiple charges for abusing a one-year-old child who was his girlfriend’s son. For the most relevant CYPA charge, the offender was sentenced to nine months’ imprisonment for slapping the victim once on the left side of his face, causing marks on his face and a bruise near his ear. Medical attention was not sought immediately, as the victim was only referred to the hospital eight days after the injuries were discovered and no injury was found at that time.

Direct comparison with Franklie was difficult given that it was a more egregious case overall, involving multiple offences against a younger victim and attracting a global sentence of six years and six months’ imprisonment with six strokes of the cane. Nonetheless, the nine months imposed for the most relevant CYPA charge – which involved a single slap – provided a useful floor. A higher sentence was warranted in the present case given that there were eight discrete acts of violence committed over four minutes as compared to a single slap in Franklie. This conclusion is further reinforced by the fact that Franklie predated the 2019 CYPA amendments which doubled the prescribed punishment.

The remaining two cases were also distinguishable. In Ma Yujie, the offender did not personally inflict harm on the victim, whereas the Offender here did. The offender in Ma Yujie was also a teacher, while the Offender held the position of principal – a role that carries greater responsibility and commands a correspondingly higher degree of trust. The breach of that trust was therefore more serious in the present case. Finally, the offender in Ma Yujie demonstrated some measure of responsibility and remorse in the aftermath of the incident by insisting that the principal review the CCTV footage and threatening to report the incident to the Police if she refused. The Offender, by contrast, showed no such remorse – she actively deceived the Victim’s father about the cause of the Victim’s injuries. As regards Alamelu, the offender had only kicked the victim once while the Offender committed a series of violent acts against the Victim. Additionally, the offender in Alamelu was a teacher, and as the Offender here held the more senior position of principal, the breach of trust was greater in the present case.

I also considered the case of PP v JDK [2025] SGDC 40 which the Prosecution mentioned in its sentencing submissions but did not rely on specifically as a sentencing precedent. That case involved a domestic worker who had abused an 11-month-old infant under her care. She pleaded guilty to three counts of ill-treatment of a child under s 6(1) punishable under s 6(6)(b) of the CYPA and was sentenced to 20 months’ imprisonment on aggregate. For one of the charges, the offender received seven months’ imprisonment for pinching the victim’s waist twice with no visible injury.

The present case was considerably more serious on the facts. The Offender committed eight distinct acts of violence across four minutes, repeatedly targeted the Victim’s head, and employed an object as a weapon. In contrast, the offender in JDK had pinched the victim twice, causing no visible injury. The nature, multiplicity, and duration of the Offender’s acts plainly placed her conduct in a higher category of seriousness than that in JDK, and a sentence of more than seven months’ imprisonment was therefore justified.

Having considered all the circumstances in totality, including the maximum imprisonment term prescribed for this offence, viz, eight years, I was satisfied that a sentence of 10 months’ imprisonment was appropriate.

Conclusion

A sentence of 10 months’ imprisonment was required to reflect the Offender’s overall criminality and the Court’s unequivocal condemnation of her actions. Parents who send their children to childcare centres do so trusting that those in charge will treat their children with a reasonable level of care and concern. That trust was gravely betrayed here. The sentence imposed serves as a clear reminder that any act of gratuitous violence against a child — and especially one committed by a person entrusted with that child’s care — will not be condoned.