Doctor allowed woman to administer Botox injections during course, his wife will help pay $30k fine
Nadine Chua
The Straits Times
Sept 4, 2025
An aesthetic doctor allowed a woman to administer Botox injections during a course on dermal fillers even though she did not have the qualifications to do so.
The doctor, Tan Say Lock, 47, was fined $30,000 on Sept 3 after he pleaded guilty to a charge under the Medical Registration Act.
The court heard that Tan's wife will pay the fine in instalments on his behalf.
Ministry of Health (MOH) prosecutor Andre Tan said on Sept 3 that in June 2018, Tan conducted a course to teach participants how to administer Botox and dermal filler injections, which Xu Hong paid $2,500 to attend.
It was not mentioned in court how many other participants there were.
During the course, Tan explained the theory of Botox and dermal filler injections to the participants and demonstrated how to administer such injections.
Tan then allowed Xu to practise administering the injections on other participants under his supervision.
In doing so, Tan abetted by intentionally aiding Xu to carry out acts reserved for a medical practitioner despite her being an unauthorised person, said the MOH prosecutor.
He added that the potential harms of Botox injections being performed by an individual who is not a registered medical practitioner include skin infection and inflammation, and asymmetrical muscle paralysis.
Tan's offence came to light in 2020, when Xu was being investigated for other crimes under the Medical Registration Act.
In response to ST's queries, MOH said Xu had earlier been sentenced to two months' jail after pleading guilty to providing Botox, hyaluronic acid and scar flattening injections as an unauthorised person.
Seeking a fine of $40,000 to $50,000 for Tan, the MOH prosecutor said: "Even if the accused's intentions had merely been to educate non-medical professionals about Botox and filler injections, he could have provided the participants only with information on how such procedures were performed and their intended purposes."
In allowing Xu to administer the injections, Tan had unnecessarily exposed the practice subjects to risks, he added.
In mitigation, defence lawyer Derek Kang said it was Tan's wife who had organised these courses, which Tan felt he could not refuse.
Mr Kang also noted that the Botox injections had been prefilled by Tan, so there was no risk of an overdose to the participants.
Anyone who intentionally abets an unauthorised person in performing any act reserved for licensed medical practitioners may be jailed for up to one year, fined up to $100,000, or both.
