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Report of the Law Reform Committee on Online Gaming and Singapore

and the social fabric, such as minors and potential addicts to gambling. It has since authorised the award of two casino licenses in Singapore.


The CCA also regulates the operational aspects of licensed casinos and includes

the provisions on the following: the making of contracts relating to the supply of goods or services for the operations of the casino; licensing of employees of the casino employed in a managerial capacity, authorised to make decisions involving the exercise of their discretion that regulate casino operations or whose work involve activities such as the conduct of gambling; the movement, exchange or counting of money or chips about the casino premise; security and surveillance of the casino; and the operation,

maintenance, construction or repair of gambling equipment.


Anti-gambling statutes


The four principal statutes in Singapore that govern gambling are the Common

Gaming Houses Act (Cap 49), the Betting Act (Cap 21), the Private Lotteries Act (Cap 250) and the Betting and Sweepstakes Duties Act (Cap 22). Each deals with a different aspect of gambling and is either prohibitory or regulatory, and a particular gambling product can fall under more than one statute. They are as follows:


Common Gaming Houses Act (Cap 49) (“CGHA”)


The CGHA governs gaming and public lotteries.54

It broadly makes it an

offence to operate or be involved or invested in a common gaming house or in a public lottery, subject to certain prescribed exemptions.55 It is also an offence to be a customer of such places or activities. The CGHA does not expressly draw a distinction between “gaming” and “gambling” since the definition of “gaming” is “the playing of any game of chance or of mixed chance and skill for money or money’s worth” under s 2.


The recent decision of PP v Peh Chye Heng56 demonstrates the applicability of

the CGHA and the extent to which it covers online gaming offences. Briefly, the accused was charged under s 4(1)(a) of the CGHA for running an Internet cafe which provided online casino gaming services to customers. In coming to its conclusion, the court noted that these online games were “games of chance which did not require skill”,57 and that the owner Peh was liable because the Internet cafe constituted a

54 55

Ie a lottery to which the public has access.

Public lotteries conducted by businesses to promote products and services, lotteries promoted by certain charities or institutions of public character, public lotteries incidental to events like trade fairs and dinners and dances, and certain types of gaming in private clubs have been exempted from the ambit of the CGHA. Additionally, as will be further noted later, various ad hoc exemptions have been granted to various entities for specific gambling events hosted by or held in Singapore since late 2002.

56 57

[2009] SGDC 100. [2009] SGDC 100.


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