When courts issue decisions establishing or clarifying sentencing guidelines, a concern is whether these guidelines should only be applied prospectively (known as “the doctrine of prospective overruling”), and if so what that prospectivity entails. In Adri Anton Kalangie v PP  SGCA 40, the Court of Appeal (“CA”) held that although as a general rule, decisions establishing or clarifying sentencing guidelines will apply both retroactively as well as prospectively, the court laying down the guidelines may, in an exceptional case, state that such guidelines will only come into effect from a specific date. In such a case, the guidelines should apply to all offenders sentenced after the date of the decision, regardless of when they had committed the underlying offence. However, they would not apply to the actual offender in the decision.
In the 19th century, illegal gaming activities managed by syndicates were part of the general crime that was rampant in Singapore (then known as the Straits Settlement). This was a serious problem as the early inhabitants of Singapore became addicted to gambling, leading to undesirable outcomes. Gambling activities came to be regarded as vices by Sir Stamford Raffles, and rules to regulate illegal public gambling were put into place.