September 2, 2026
Our Cases

Singapore Criminal Lawyers Led by Johannes Hadi Secure Lev Panfilov’s Acquittal of Rape Charges

Singapore criminal lawyers Johannes Hadi, Eugene Thuraisingam and Seraphine Loh acted in the successful appeal of Lev Panfilov against his conviction (Public Prosecutor v Panfilov, Lev [2025] SGHC 249), the Court of Appeal allowed the appeal and set aside his conviction on all four charges — one count of outrage of modesty, one of sexual assault by penetration and two of rape — for which the High Court had sentenced him to 11 years and 6 months’ imprisonment and 12 strokes of the cane. Johannes Hadi led arguments on behalf of the appellant.

Can a rape conviction stand when the complainant’s own account is the only direct evidence of what happened — and that account shifted on the very point that mattered most? The Court of Appeal has answered no.

On 2 September 2026, having heard arguments from a team of Singapore criminal lawyers led by Johannes Hadi, a coram comprising the Honourable the Chief Justice Sundaresh Menon, and Justices of the Court of Appeal Justice Ang Cheng Hock and Justice Sushil Nair, allowed Lev Panfilov’s appeal and set aside his conviction on all four charges.

BACKGROUND

The High Court had convicted Panfilov, a Singapore permanent resident and former Wah!Banana scriptwriter-actor, of one count of outrage of modesty, one count of sexual assault by penetration and two counts of rape, arising from an encounter in January 2021 with a woman he had met on Tinder. Justice Pang Khang Chau sentenced him to 11 years and 6 months’ imprisonment and 12 strokes of the cane: Public Prosecutor v Panfilov, Lev [2025] SGHC 249.

THE APPEAL

Panfilov’s appeal, led by criminal lawyer Johannes Hadi, turned on a single question: did the complainant’s evidence meet the “unusually convincing” standard Singapore law demands where a conviction rests on one witness’s word and nothing else? That standard, drawn from AOF v Public Prosecutor [2012] 3 SLR 34, holds that a complainant’s testimony can found a conviction beyond reasonable doubt without corroboration only if it is unusually convincing — a high bar, and the one the defence argued the prosecution’s case did not clear.

The criminal lawyer team pointed the court to inconsistencies it argued the trial judge had not given sufficient weight: the complainant told her doctor she had screamed during the assault, then testified at trial that she had wanted to scream but had not — even though a flatmate in the next room heard nothing; she asked her doctor for a memorandum recording her injuries, then asked for the visit to be struck from her records when the doctor declined to provide one; and CCTV footage taken shortly afterwards showed her walking normally, composed and without a hair out of place, at odds with the account she gave of the attack.

THE DECISION

The Court of Appeal allowed the criminal lawyer team’s appeal in its entirety and set aside Panfilov’s conviction on all four charges.

The Court largely agreed with the defence’s arguments. The Court observed that there is indeed a “requirement that the Prosecution prove its case beyond all reasonable doubt”, and that it is “incumbent on the Court to apply this standard with utmost rigour and respect”. On the facts of this case, the Court observed that “there are inconsistencies which undermine the core elements of the complainant’s evidence, because of which the complainant’s evidence falls short of being unusually convincing”.

SOME SALIENT POINTS

First, the “unusually convincing” standard does real work. Where a conviction rests on a complainant’s uncorroborated account, that account must be unusually convincing before it can establish guilt beyond reasonable doubt. It is not enough that the court believes the complainant on balance; the threshold is a demanding one.

Second, small inconsistencies can add up on appeal. Discrepancies that appear minor in isolation may, taken together, raise a reasonable doubt — particularly where they bear on the central events and where the trial court did not fully grapple with them. An appellate court is entitled to revisit the weight the trial court gave to such matters.

HOW WE CAN HELP

A professional Singapore lawyer team is essential to identifying and articulating the true gaps in the objectiv evidence and a complainant’s account.

Our criminal defence lawyering practice represents individuals at every stage of the criminal process, from investigation and trial through to appeals against conviction and sentence. If you are facing a criminal charge, or considering an appeal against conviction or sentence, contact us for a confidential discussion.

RELATED READING