text: Following court cases in the UK however, the High Court of Singapore then found in the obiter dicta of Tang Kin Hwa v. Traditional Chinese Medicine Practitioner Board (2005) that there was no material difference between the test of “real likelihood” and “reasonable suspicion”, which was again disagreed upon by a different judge in the case of Re Shankar Alan s/o Anant Kulkami (2007), who found that there was a difference as reasonable suspicion is far less stringent, requiring a lower standard of proof than satisfaction on a balance of probabilities, and thus expressed preference for the reasonable suspicion test over the real likelihood test.