CWS’ proposal for changes to be made to the current state of law as captured in the Animal and Birds Act (“ABA”) and the Cat Management Framework (“CMF”) is set out below:

1. The penalties for the breach of duty of care under Section 41C of the ABA and acts of cruelty under Section 42 of the ABA should be increased three-fold for offences by individuals and two-fold for offences by businesses and include a restitutionary element in the sentencing
2. The Disqualification Order should have a minimum period of 60 months with no maximum time limit.
3. The regulatory regime under the CMF must penalise irresponsible cat owners causing disamenities due to failure to sterilise their pet cats

We expand on our views below.

1.Breach of duty of care and acts of cruelty under the ABA – Penalties to be increased for individuals and businesses and restitution to be adopted in sentencing

Section 41C of the ABA sets out what a breach of duty of care toward an animal is and the penalties for the same –

Duty of care of animal owners

41C.—(1)  Every owner of an animal — (a)must take reasonable steps to ensure that — (i)the animal is provided with adequate and suitable food and water, taking into account its dietary needs; (ii)the animal is provided with adequate shelter; (iii)the animal is not kept in confinement, conveyed, lifted, carried or handled in a manner or position that subjects the animal to unreasonable or unnecessary pain or suffering; and (iv)the animal is protected from, and rapidly diagnosed with, any significant injury or disease; (b)must not abandon the animal, or cause or permit the animal to be abandoned, whether permanently or temporarily, without reasonable cause or excuse; (c)in the case where the animal is missing, must make reasonable efforts to recover the animal; and (d)must take reasonable steps to ensure that the animal is cared for in accordance with the codes of animal welfare applicable to the animal. (2)  Any person who fails to comply with subsection (1)(a), (b) or (c) shall be guilty of an offence. (3)  A person who is guilty of an offence under subsection (2) shall be liable on conviction — (a)in the case where the person commits the offence in the course of carrying on, or employment or purported employment with, an animal‑related business — (i)for a first offence, to a fine not exceeding $40,000 or to imprisonment for a term not exceeding 2 years or to both; and (ii)for a second or subsequent offence, to a fine not exceeding $100,000 or to imprisonment for a term not exceeding 3 years or to both; or (b)in any other case — (i)for a first offence, to a fine not exceeding $10,000 or to imprisonment for a term not exceeding 12 months or to both; and (ii)for a second or subsequent offence, to a fine not exceeding $20,000 or to imprisonment for a term not exceeding 2 years or to both. (4)  For the purpose of subsection (3), a person is a repeat offender if the person who is convicted, or found guilty, of an offence under subsection (2) has (whether before, on or after 16 January 2015) been convicted or found guilty on at least one other earlier occasion of an offence under section 42(1)(f) in force immediately before that date.

Section 42 of the ABA sets out what an act of cruelty toward an animal is and the penalties for the same –

Cruelty to animals

42.—(1)  Any person who — (a) cruelly beats, kicks, ill‑treats, over‑rides, over‑drives, over‑loads, tortures, infuriates or terrifies any animal; (b) causes or procures or, being the owner, permits any animal to be so used; (c) by rashly or unreasonably doing or omitting to do any act, causes any unnecessary pain or suffering or, being the owner, permits any unnecessary pain or suffering to any animal; (d)employs or causes or procures or, being the owner, permits to be employed in any work of labour, any animal which in consequence of any disease, infirmity, wound or sore, or otherwise, is unfit to be so employed; or (e)causes, procures or assists at the fighting or baiting of any animal, or keeps, uses, manages, or acts or assists in the management of any premises or place for the purpose, or partly for the purpose, of fighting or baiting any animal, or permits any premises or place to be so kept, managed or used, or receives or causes or procures any person to receive money for the admission of any person to the premises or place,shall be guilty of an offence. (2)  For the purposes of subsection (1), an owner is deemed to have permitted cruelty to an animal, if the owner has failed to exercise reasonable care and supervision in respect of the animal. (3)  Nothing in this section applies to the commission or omission of any act in the course of the destruction, or the preparation for destruction of any animal as food, unless that destruction or preparation was accompanied by the infliction of unnecessary suffering. (4)  A person who is guilty of an offence under subsection (1) shall be liable on conviction — (a)in the case where the person commits the offence in the course of carrying on, or employment or purported employment with, an animal‑related business — (i)for a first offence, to a fine not exceeding $40,000 or to imprisonment for a term not exceeding 2 years or to both; and (ii)for a second or subsequent offence, to a fine not exceeding $100,000 or to imprisonment for a term not exceeding 3 years or to both; or (b)in any other case — (i)for a first offence, to a fine not exceeding $15,000 or to imprisonment for a term not exceeding 18 months or to both; and (ii)for a second or subsequent offence, to a fine not exceeding $30,000 or to imprisonment for a term not exceeding 3 years or to both.

From the face of the penalties, the following can be observed –

(a) An individual’s breach of duty of care is considered less reprehensible than an act of cruelty under the law. The former offence attracts a fine of $10,000 and/or 12 months jail for a first-time offender, while the latter a fine of $15,000 and/or 18 months jail for a first-time offender.
(b) If the offender is a business, then there is parity of fine at $40,000 and/or 2 years jail for a first timer, and $100,000 and/or 3 years jail for a repeat offender.

1A. Penalties for breaches by individuals to be increased three-fold

CWS’ view is that the penalty thresholds are grossly insufficient because they do not adequately capture the reprehensibility of the actions of the offenders against sentient and defenseless animals; and are so low that they do not have any valuable deterrent effect on a potential offender. Further, CWS urges that there be assistance provided to the individuals who have to bear the burden of care for the victim animals.

Although animals are considered “property” under the law (like kitchen appliances) the fact remains that they are sentient beings with an inability to protect themselves therefore requiring protection from adults and the state. Much closer to a child than an airfryer.

It follows that there must be additional rules and laws that protect them. One way of doing this is prescribing penalties of such severity for acts of harm committed agains them that it would deter a person from committing such acts. It must cause more than pause; it must prevent such an act.

Courts act within the bounds of the laws and in this case, they are operating in such a small boundary space that the first sentence meted out for the wanton abuse of 5 cats over 20 months was a mere 14 months for Barrie Lin (who had pled guilty to three charges of cruelty to cats and was on trial for 2 more cats that had died). This has since been increased to 27 months on appeal by the High Court, as reported on 9 July 2025.

A man who abused cats for 20 months first received a jail term of only 14 months, which has since doubled to 27 months on appeal by the Prosecution. Sit with those numbers for a moment.

CWS view is that the thresholds must be increased – the Court must have a wider space to work within when determining the proportionality of the punishment considering numerous factors like the length of time of the actions, the number of animals harmed, the depravity of the actions, the mental condition of the offender to consider and his culpability. The sentences that the Court metes can more comprehensively capture these factors with a wider range of power and be more representative to how Singapore has matured as a society, how we treat all our living beings and how we have taken a collective stance against the harm of the same.

1B. Penalties for offences committed by businesses to be increased two-fold

Extending from this is the need to revise the thresholds for offences by businesses. The current thresholds are the same under Sections 41C and 42 – $40,000 and/or 2 years jail for first time offenders and $100,000 and/or 3 years jail for repeat offenders.

The element of profit will be a primary reason why businesses already attract a higher penalty than individuals. The profit is also based on volume of animals under a person’s care or control, and hence the greater the potential for harm.

CWS proposal is that businesses continue to be held to a higher penalty threshold than individuals by increasing their thresholds two-fold to
$80,000 and/or 4 years jail for first time offenders and $200,000 and/or 6 years jail for repeat offenders. This will capture the greater duties and obligations that should be imposed on businesses due to their profit margin and volume of animals.

1C. Need for a restitutionary element in sentencing

At present, there is no assistance rendered to the victim animals that survive. They should be under AVS’ care as subject of an active investigation, but we know that private individuals do take over the care of some victim animals. For example, in the case of the multiple cats and kittens that fell from a house in Bedok Reservoir, independent rescuers took over the cats/kittens’ care and bore their medical bills personally or in the case of the last cat slammed against the wall by Barrie Lin, the caregiver took the cat (Socks) to the vet and cared for him after at her personal costs. The offenders bore no further burden of care, nor did they contribute in any way to the financial burden their actions imposed upon a third party.
If an individual is fined, the monies are not channelled to the victim animals.

CWS proposes that AVS be given a discretion to provide for some financial restitution to an individual who has had to bear the financial brunt as a result of these offences. This could be limited to the medical care of the harmed animal and it goes without saying that the carer must provide all necessary evidence. Such a mechanism will trace and acknowledge the transfer of the burden of care and keep the offender accountable for the aftermath of his actions as well.

1D. Note on potential need for Regularisation of Penalties by Individual Offenders

CWS’ also recommends considering regularising the penalties for breach of duty of care (fine of $10,000 and/or 12 months jail for a first-time offender, and a fine of $15,000 and/or 18 months jail for a repeat offender) and cruelty (fine of $15,000 and/or 18 months jail for a first-time offender, and a fine of $30,000 and/or 3 years jail for a repeat offender) to have the same threshold.

From its wording, the law appears to consider breach of duty described in more “passive” actions like neglect and abandonment to be less reprehensible than cruelty which describes more “active” actions like a physical act of kicking / beating the animal.

CWS’ view is that there is no material difference in the two. We believe that all actions/inactions fall within the same spectrum of harm inflicted upon an animal and should therefore be subject to the same penalty thresholds.

To illustrate, we refer to the cases of cats being abandoned and left to starve in flats by their owners in just the past two years. The following were cases on Section 42 on cruelty, and not Section 41C on neglect –

(a) In the case of Danial Sukirman, he was jailed for 20 days for causing “unnecessary pain and suffering” to the 43 cats by failing to provide adequate food and water and leaving them unattended between August and November 2021 in a flat in Ang Mo Kio. https://www.channelnewsasia.com/singapore/neglected-cats-no-food-water-20-days-jail-4294016

(b) In the case of Khairulnizam Khan Kamalrozaman, he was fined $10,000 for leaving his pet cat to starve by omitting to provide enough food and water for the cat on a regular basis between Dec 25, 2020 and Feb 2, 2021.
https://www.channelnewsasia.com/singapore/man-did-not-feed-pet-cat-over-month-died-mummified-carcass-animal-cruelty-3244026

Had Danial been caught in August/September 2021 would the cats’ conditions have been considered bad enough to be an act of cruelty with unnecessary pain and suffering? Had Khairulnizam’s cat been rescued on 28 December 2020 instead of its mummified carcass being found February 2021, would this have been neglect or cruelty?

The actions were the same – it was only time that led to the state the animals were subsequently found in. The consequences were the same – the animals starved and either died or were emaciated. Was the intention different? How would one prove that a person only intended to ignore his cat’s basic biological needs for 3 days and not the 3 month period till he got caught?

Let’s consider another example – the newly introduced Cat Management Framework requires a cat owner to keep their cats safely and securely indoors. It’s a positive duty imposed on the owner. What happens if a cat owner refuses to mesh their windows resulting in more than one pet cat falling to its death. Is there a difference in the inaction of that person from the person who throws a cat down? Perhaps one is more inclined to demand stiffer penalties for the man who threw the cat down than a person who did not close their windows or mesh them. Does that change if a third cat falls from the unmeshed window of a recalcitrant owner? How about a fourth?

2. The Disqualification Order should have a minimum period of 60 months with no maximum time limit.

The Disqualification Order (“DO”) provided for under the ABA has a maximum term of 12 months. This is blatantly insufficient and again, useless as a practical deterrent to any person who harms animals. CWS’ view in 2021 formed in the light of hte cases of Leow Wei Liang who slashed and harmed over 10 community cats, and the case of Clement Chia who abused his dog for over a year remains the same.

The DO would have more teeth and utility if:

(a) the term is increased to a minimum of 60 months (5 years) and a maximum of a lifetime-disqualification; and

(b) more powers are granted to the investigation officer or other appropriate authority to act together with a mental health practitioner (where necessary and at the Court’s discretion) to regularly check-in with the freed individuals to assess their mental state.

It would be open to the said authority and mental health practitioner to recommend the term of the DO either be increased or even decreased if appropriate.

The proposed 5 year period of follow-up provides the authorities sufficient time and data to establish a pattern of behaviour or make meaningful observations as to the mental state of the freed individual and their ability to own a pet. It will also allow for there to be checks on whether animals have been brought in by other persons in the same residence, to prevent any circumvention of the order.

CWS further suggests that there be a repository of names of individuals who are under a DO made available to both pet shops and animal welfare groups with whom rehomers can conduct a check when looking to rehome their cats.

3. The regulatory regime under the Cat Management Framework must penalise irresponsible cat owners causing disamenities due to failure to sterilise their pet cats

The Cat Management Framework (CMF) took effect on 1 September 2024 and will require complete adherence by 30 August 2026. AVS has not implemented mandatory sterilisation despite consistent calls for the same based on clear evidence that such a mandate is needed. It has also not announced what the penalty framework would be for those who infringe the framework.

Mandatory sterilisation is imperative to allow for greater strides to be taken in improving the welfare of our Singapore cats. The immediate impact is that there will be a smaller population of cats allowing for more resources to be given to each cat. There will be reduced burdens of care on caregivers, rehomers and fosterers and this will bring us closer to seeing sustainability of care for the cats.

Further, mandating sterilisation will directly reduce cases of overpopulation in homes, abandonment, caterwauling, spraying and even roaming thereby reducing the burden on public authorities like AVS, NEA and Town Councils and animal welfare groups for feedback resolution.
CWS works closely with AVS’ Engagement Team on feedback resolution and such cases form a large proportion of the overall caseload for all our teams. At present, there is no way to solve the root cause of these issues without a mandate for sterilisation. The failure to mandate sterilisation was truly a missed opportunity for the lawmakers and statutory bodies to effect changes that would help themselves and the cats at the same time.

There remains one final potential opportunity to do so – the penalty framework for the CMF. When cat-related fedback is sent to CWS, we engage with the relevant stakeholders and take an advisory approach to resolution because CWS has no powers of investigation or enforcement under the law. If there is an offence, this is escalated to the Enforcement and Investigations team within AVS. From that point on, the case, its strength and all processes fall into a black box.

CWS’ view is that AVS must ensure that its penalty framework must have teeth. It should not be content to just issue advisories. That would already have been issued by CWS / AVS engagement teams and fallen on deaf ears so this is just a waste of time.

Instead, AVS should have a clear mandate to direct meaningful reparative actions – like sterilisation of pet cats and even meshing of windows and the failure to do so should be an offence. This is AVS’ opportunity to be empowered to make decisions that will have real, meaningful impact not just on cats, but those affected by irresponsible individuals, and on public service employees who manage this feedback. This decisiveness and authority will result in a deeper trust placed in our public authorities and evidence that they do care about making meaningful change for our community.