Re Shankar Alan s/o Anant Kulkarni

Re Shankar Alan s/o Anant Kulkarni
The Supreme Court Building, photographed in February 2007
Court	High Court of Singapore
Full case name	Re Shankar Alan s/o Anant Kulkarni
Decided	27 October 2006
Citation(s)	[2006] SGHC 194, [2007] 1 S.L.R.(R.) 85
Court membership
Judge sitting	Sundaresh Menon J.C.
Case opinions
The applicable test for apparent bias is that of a "reasonable suspicion of bias", which is materially different from the test of a "real likelihood of bias".

Re Shankar Alan s/o Anant Kulkarni was a 2006 administrative law judgment in which the High Court of Singapore quashed a decision made by the Disciplinary Committee of the Law Society of Singapore against a lawyer, Alan Shankar s/o (son of) Anant Kulkarni. The Disciplinary Committee had found Shankar, who was a solicitor, guilty of grossly improper misconduct under the Legal Profession Act. Shankar applied to the High Court for judicial review on the ground that the Committee's ruling was affected by apparent bias.

Judicial Commissioner Sundaresh Menon considered the differences between two commonly used tests for apparent bias: the "real likelihood" and "reasonable suspicion" tests. He held that there were notable differences between the two tests, contrary to the previous view taken by a different High Court judge in Tang Kin Hwa v. Traditional Chinese Medicine Practitioners Board (2005). He took the view that the reasonable suspicion test was the applicable test in Singapore.

Two other legal issues were also considered, namely, whether the Disciplinary Committee had applied the wrong standard of proof, and whether it had shown a sufficient degree of detachment. Menon eventually decided the case in favour of Shankar and quashed the Committee's ruling.