Thursday, April 03, 2008

 
KTV Licensing Guidelines

Sometimes, in the course of legal research for a client, you learn all sorts of interesting stuff. Today for example, I learnt about the regime governing licensing of karaoke bars in Singapore. (I should add that you only learn interesting stuff if you have interesting clients)

For the uninitiated, there are 2 types of karaoke bars in Singapore. The first is the normal western style bar with the karaoke system in the general bar area. Patrons take turns to select and sing songs in front of everyone else in the bar. This is termed a "Family KTV".

The second type consists of many small rooms for groups of patrons and dozens of female staff whom patrons can choose to have sit with them for, er, conversation. These are euphemistically called "Business KTVs". In Singapore, the Police have come up with a set of guidelines for KTVs and a quick perusal of these guidelines makes it clear that they are aimed primarily at Business KTVs.

For example, condition 16 states: "The Licensee shall ensure that all staff, employees, performers, models, contestants and participants of any event are not indecently dressed or exposed." I wonder why this has to be specifically spelt out?

Condition 21 states that unless approval has been given, "the licensee shall not permit any person in the licensed premises to perform the duties of a hostess" and then very helpfully explains that this means "provide companionship to one or more patrons through consumption of drinks or conversation" (apart from taking orders, serving drinks & other incidental conversation).

Perhaps Condition 9 was drafted while keeping the above 2 conditions in mind. Condition 9 provides that "the licensee shall ensure that there is a clear view of the KTV rooms from the outside ... that blinds, curtains, decorations and other items or equipment which obstruct such view are not used."

Most explicitly, condition 17 states:
"... the Licensee shall prohibit any staff, employees, performers, models, contestants and participants of any event from being:
(a) Nude or partially nude;
(b) Topless;
(c) Dressed in attire that provides bare, transparent or translucent exposure of any part of the genitalia, nipples, breast/s ...
... an exception is made for those performers, models, contestants and participants who do not mingle with the patrons, who are permitted to be dressed in attire that provides bare, transparent or translucent exposure of any part of the breasts ... other than ... the portion of the breasts bounded by the two lateral lines as shown in Annex A ..."

So exactly how much cleavage / breasts can you show in your KTV? Well this is what the Annex A picture looks like. Shocking isn't it? First of all, any girl who looks like that is most certainly not going to be able to find employment in a KTV. And if she does, we certainly want her to be wearing a LOT more than just the prohibited area in Annex A!

Secondly, isn't Annex A missing something? They've drawn the breasts and the nipples. What happened to the areola? Annex A is ambiguous! Is the prohibition against nipples only? Does that mean your KTV performer can show off her areola above the nipples?

And finally, why prohibit showing any part of the bottom of the breasts? Why can you reveal the top of the breasts up to just before the nipples but not any part of the bottom of the breasts after the nipples? Have the Police discovered that the bottom half of the breasts are somehow special when compared with the top half of the breasts?

Perhaps one day all these issues will be the subject of a massive and vigorous court battle. At least the Associates will enjoy the discovery process in this case more than most others.

Comments:
Hmm, interesting...

I have been under the impression that you could do a lot "more" in a business KTV....

DP
 
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