The defendant was charged and convicted of being in paid employment without an employment permit.
Held, on review:
(i) All penal statutes must be construed strictly.
(ii) The absence of any statement of criminal liability and of a penalty in a statute prima facie indicates that no crime was intended 5 to be created by the statute.
(iii) As the Immigration and Deportation Act, Cap. 122, did not prescribe any penalty or impose any criminal liability for engaging in paid employment without an employment permit, the accused was convicted of an offence unknown to law, and the 10 conviction was therefore to be quashed.