A Singapore court has dismissed an application by a woman accused of conspiring to make false COVID-19 vaccination records, seeking disclosure of four categories of material from the prosecution in her ongoing trial.
The accused, Iris Koh Hsiao Pei, faces seven charges of criminal conspiracy involving alleged false representations to the Health Promotion Board that patients had received COVID-19 vaccinations.
In Public Prosecutor v Iris Koh Hsiao Pei (2026) SGDC 359, District Judge Paul Quan ruled that Koh had failed to establish reasonable grounds to believe that the prosecution possessed relevant material which it had not disclosed.
Koh faces seven charges of criminal conspiracy under section 120B of the Penal Code 1871 involving alleged agreements with Dr Jipson Quah, his assistant Chua Cheng Soon, Thomas, and/or patients to make false representations to the Health Promotion Board that patients had received COVID-19 vaccinations.
The alleged representations were intended to have the patients recorded as vaccinated in the National Immunisation Registry.
Koh sought disclosure in four broad categories: material relating to a patient’s mobile phone and Telegram communications; information concerning Ms Geno Ong Kay Yong and the origin of the investigation; records relating to the determination of vaccination status in the National Immunisation Registry; and material concerning her remand.
The court found that Koh had not provided reasonable grounds to displace the presumption that the prosecution had complied with its disclosure obligations under sections 221A and 221B of the Criminal Procedure Code.
On the first category, Koh sought a full forensic extraction report of the mobile phone belonging to patient Gary Tho Kong Chong, together with records of how the device had been handled. However, the prosecution only possessed a readable copy of the extracted data and did not have a full forensic extraction report.
The court also noted that Tho had testified that he used another phone to photograph a vaccination vial during his second vaccination with Dr Quah. He had been unable to locate the photograph, which was therefore not in the prosecution’s possession.
On the second category, the court found no basis to require disclosure of material relating to Ong or the origins of the investigation. The prosecution had stated that it possessed no material suggesting Ong was an informant or involved in initiating the investigation.
Judge Quan also rejected the suggestion that the prosecution was required to disclose information about its charging decision based on the contents of Tho’s phone, noting that there was no general obligation to disclose the reasons behind prosecutorial decisions.
Regarding the third category, the court found that the prosecution did not possess the requested material concerning the Ministry of Health’s internal decisions on changes to vaccination status in the National Immunisation Registry. The judge also found that such material did not undermine the prosecution’s case or support Koh’s defence.
For the fourth category, the prosecution stated that it did not possess the requested remand-related material, apart from custody and hospital footage that was no longer available because it had been routinely overwritten.
The judge held that the prosecution’s disclosure obligations did not extend to material outside its possession or knowledge, nor did they require it to search for additional material in the hope of assisting the defence.
He said the disclosure process was not intended to allow a fishing or trawling expedition through unused material in the speculative hope of finding a defence.
The court consequently dismissed Koh’s application in its entirety.
The judgment was delivered on 29 October 2026 by District Judge Paul Quan.
Prosecutors Timotheus Koh, Timothy Ong and Thaddeus Tan of the Attorney-General’s Chambers appeared for the Public Prosecutor. Koh represented herself.
This is an unofficial case summary prepared by LexBru for informational and educational purposes only. It has not been reviewed, approved or endorsed by the Singapore Courts. Please refer to the full judgment https://www.elitigation.sg/gd/s/2026_SGDC_359 published on the Singapore Courts website for the Court’s full grounds of decision.