Mr Speaker, Sir, I wish to thank Members who have spoken. It is clear that we have a spectrum of views. There are some like my colleagues, the Minister for National Development and Dr Ong Chit Chung, who would have favoured immediate cutting off of all appeals. There are others who felt that the provisions perhaps go too far. This shows that perhaps the approach taken in the Bill is a good balance. Let me now deal with the various points raised by Members. I will try to take them in the order of the speakers. First, Mr Davinder Singh made several interesting observations. First, he did not agree with the approach taken, with regard to the transitional provision, and would advocate an approach which would allow appeals for all proceedings which have been commenced, whether at High Court stage or Court of Appeal stage. In other words, all pending appeals should be caught by the transitional provision. My first comment is that this will mean that there will be a considerable delay in the practical operation of the new law. I think he himself pointed out that it takes many years for cases to be heard. Secondly, I wish to point out that the transitional provision which we have is not too different from the transitional provisions of some other countries. We have looked at the transitional provisions in Malaysia when they cut off appeals to the Privy Council and the transitional provisions in the Australian legislation when they abolished appeals to the Privy Council. The approach taken in our Bill is, in fact, similar to the approaches taken by Malaysia and Australia. In fact, we can say that our approach is wider. The third observation I would like to make is that obviously where the Court of Appeal gives a decision, the losing party is unlikely to get the winner's consent. That is why we have taken the approach in the transitional provision that if the Court of Appeal's decision is given before the commencement of the operation of this Act, then appeals without consent can still proceed. But the point I want to underline is that the approach taken in our transitional provision is not unprecedented, as there are good models on which they are based. Another point is what I would call the argument of intolerable burden placed on lawyers. I have listened with interest to his exposition of this point. But first I think it is necessary to emphasize that the consent approach in this Bill is not giving consent if you lose. It is consent given in advance to a system. In other words, the parties agree before the matter is heard by the Court of Appeal that the consent to the dispute going to the Privy Council without knowing whether they are going to win in the Court of Appeal. I do not quite understand his point. I will disagree with his proposition that this places a special or impossible burden on lawyers. He has asked how will a lawyer advise a client who comes to the lawyer and says, "Should I consent in a particular case?" I would assume that if a client approaches a lawyer and asks for advice as to whether he should consent, I would expect that the lawyer would advise him to the best of his ability, outline the risks, advantages, disadvantages, pros and cons of the law. But the final decision is up to the client. And the client then will instruct the lawyer. I do not see how this situation is different from the countless other situations which a lawyer is faced everyday. Clients come and ask for advice. "Should I sue? Should I institute action in the courts?" And if he institutes action in the courts and he loses, he comes and asks for advice, "Should I institute an appeal to the Court of Appeal?" Or if he is offered settlement for a lower sum, "Should I accept the settlement which is of a low value or should I appeal?" In all these cases, the lawyer really has no crystal ball. Neither the lawyer nor anyone can guarantee what the outcome of litigation will be. Litigation has its risks. And I cannot see any lawyer guaranteeing to his client, "Yes, you will win." If that is the case with the countless situations which lawyers are faced when clients come and ask for advice, I do not think this situation is very different. Nor is it different from cases, which are plentiful now, where existing contracts may have provisions for arbitration and a client asks for advice, well in advance of any dispute arising, whether he should consent to this particular provision. In all these cases, including the case presented by Mr Davinder Singh, I think the lawyer would have to advise to the best of his ability and the client would have to make up his own decision. The other point raised by Mr Davinder Singh was his observation that this approach in the Bill means that a development of the law is not in the hands of the court but of the parties in this sense, that if there is a complex or complicated question of law which might deserve a hearing and exposition of the law in Privy Council, it really is dependent now on both the parties, which means one party can prevent it from going out. That may be so. But I do not see how that is really a serious objection to the approach. Because even as it is now, whether a case involving interesting or complicated or a novel point of law, whether it goes up to a higher Court of Appeal or to the Privy Council really is dependent on the parties. And the losing party whether he appeals or not is going to decide on a variety of factors, not only on the basis of the advice he gets on the probabilities of his success but on other factors, costs, tactical considerations and so on. But he is probably going to decide on the basis of what is in his own interest rather than whether he is going to contribute to a great development of law in a particular branch of law in Singapore for future litigants. May I now turn to points raised by the Chairman of the GPC, Dr Arthur Beng. His first point was what would happen to existing agreements. My answer to that is, first of all, we cannot assume that all those who entered into existing contracts had entered into those agreements on the assumption that Privy Council would be the final Court of Appeal. But in any case, the important point is that we are not stopping the parties to those existing agreements from still agreeing under this new Bill for the disputes to be resolved by appeals to the Privy Council. It is still open to them. We are not restricting them and they can subsequently still agree by supplementary agreement. Secondly, as to Privy Council judgments already given, whether they would be still binding on our courts, if I am not mistaken, the previous judgments will still be binding on our courts. The third point that he raised was this. Will businessmen be prompted or prodded into inserting provisions on choice of law? And they might make choice of law in the United Kingdom or other countries and resulting in more disputes being heard in the United Kingdom. Whether this will happen or not, I am not sure. But I would assume that for local contracts, I do not see why they would want to insist that the choice of law would be United Kingdom. For international contracts, the present practice is, in fact, that the parties are already inserting provisions as to choice of law. The important thing to note is that the amendments proposed before the House do not circumscribe the existing practice. In other words, whatever is the practice of choice of law provisions, they are still free to continue with the practice. And if they want, they can agree that the matter can go up to the Privy Council. I think it may be necessary for me to make a distinction between provisions in contracts on choice of law and where the dispute is going to be heard. These are two different points and one does not follow from the other necessarily. In other words, if contracting parties decided that it will be United States law or New York law which shall govern the contract,it does not automatically follow that the courts in New York will have jurisdiction because whether the courts in New York will have jurisdiction would be dependent on many rules governing the jurisdiction in the United States' courts, whether the cause of action arose there and so on. Then I refer to the points raised by Mr Shanmugam. He has dealt with many of the points raised by Dr Lee Siew-Choh. He referred to investor confidence and my reply to his comments on that is that it is precisely because of considerations like that that we have not completely abolished appeals to Privy Council and we have provided for a mechanism where investors and others who consider it important for them to have appeals to Privy Council to arrange their agreements and other documents in such a way that they can still retain appeal to the Privy Council. He raised a technical point as to whether there is a need to amend the Supreme Court of Judicature Act. This is a matter which I would obviously have to take up with the Attorney-General and I assure him that it will be looked into. But the major substantive point which Mr Shanmugam raised was that because the Civil Law Act provides that in commercial law matters, English law shall be applicable in Singapore. Our approach should be to provide that there will be automatic appeals to the Privy Council in such matters. At first hand, this may seem an attractive idea but upon closer scrutiny I am not in favour of that approach because we must make a distinction between the applicable law on the one hand, and on the other hand, the dispute settlement procedure and the judicial process. The two are separate and should be kept separate. If I may just give a hypothetical example. Suppose we decided as a matter of law that our securities in stock market law had to be reformed and we concluded that the United States' law is the best in the world. If we legislated to provide that in that area he United States' law shall be applicable in Singapore, that is to say one thing but it does not follow that in that area of the law we must have appeals up to the United States Supreme Court. The two are different. So you may have the Civil Law Act making English law applicable on a variety of subjects but it does not follow that you must have appeals to the Privy Council because of that. I should also point out that there is no difficulty for judges in Singapore deciding what is the applicable English law on any particular point. It may also require us to note that under the Civil Law Act although it provides that the commercial law of England applies here, it is also provided that this is subject to modifications and adaptations due to local circumstances in Singapore. And indeedthe applicability of English law is also subject to whetherthere are local statutes on the matter, and indeed in many areas, corporate law, banking law, we have our own legislation. Now may I come to the points raised by Dr Lee Siew-Choh. I need not answer all his questions as Mr Shanmugam has dealt with his other points. One point raised by both Dr Lee Siew-Choh and Mr Chiam is that there have been very few dissenting opinions. I recognize that, but at the same time, as I have pointed out in the last sitting on the Committee of Supply debate on the Judicature, we are going to have provisions for more judges and I pointed out that this year there will be provision for some 17-19 judges and a total number of 22-23 courts will be available by 1990. So the number of judges will increase and we cannot expect that there will never be dissenting judgments in the future. And we cannot assume that there will always be unanimous opinions in criminal matters involving death penalty and life imprisonment. Indeed, we can foresee that if a judge feels very strongly that he disagrees with his two brother judges, then he can record his dissent. Sir, Dr Lee Siew-Choh says we do not value life and liberty. Then can I ask him why is it we have provided that in death penalty and life imprisonment, there can still be appeals to Privy Council? Dr Lee made the curious observation that this Bill has been sprung as a surprise because Mr Jeyaretnam has announced at the press conferenece that he is going to bring legal action against the Government but he forgot to mention that Mr Jeyaretnam gave his press conference after this Bill was introduced and he does not explain why, although the Privy Council judgment was issued last year, Mr Jeyaretnam has not done anything between then and now. Mr Chiam's remarks really come as a surprise. I think he should decide what his stand is. Sir, this is what he said on 17th February, and I quote: 'I would like to go on record that I think it is high time that Singapore, after over 20 years of our judicial system in Singapore, should grow up and not be tied to the apron strings of the Privy Council.' I think sometimes, Sir, he speaks from the heart. I think that was the occasion. And sometimes when he has the script, he speaks to the gallery. So I feel tempted to ask: will the real Mr Chiam, please put up his hand? Both Mr Chiam and Dr Lee asked, will the Government give advance notice whether it is going to consent? Obviously we cannot. It must depend on the transaction, it must depend on the case. Sometimes the Government may be the plaintiff, the Government may be the prosecutor and sometimes maybe the defendant. It depends on the individual case. His comments on a permanent Court of Appeal. This was thoroughly discussed in response to comments made by the Chairman of the GPC during the Committee of Supply debate and I think my views on that are known. He asked whether the appeals listed in the statistics are there many which involve disciplinary cases. I do not have all the breakdown but the civil cases listed for that period include 6 show-cause discipli- nary proceedings of which only two were allowed, according to my records. Sir, I believe I have answered most of the comments. If I have missed out any, I shall be grateful if Members point it out.