Can a prize promotion be run that is based on skill?
Yes, a prize promotion based on skill can be run in Singapore so long as it amounts to a 'game of skill' (as explained below) and does not fall within the ambit of the CGHA and the RGA.
The CGHA defines a 'game' as being a game of chance or of a combination of chance and skill for a money or money’s worth, and 'lottery' as any game, method, device, scheme or competition whereby money or money’s worth is distributed or allotted in any manner depending upon or to be determined by chance or lot, whether the same is held, drawn exercised or managed within or outside of Singapore. 'Public lottery' means a lottery to which the public or any class of the public have access or may have access to, and every lottery shall, until the contrary is proved, be deemed to be a public lottery. Please refer to the Extra-territoriality section for the definition of 'game of chance' in the RGA.
As of yet there is no published case law in Singapore discussing these definitions. However, traditionally, games of chance or of a combination of chance and skill include for example lotteries, wagers and casino-style games such as roulette, while games of skill include for example, chess and checkers. Therefore, it could be assumed that in order for a game to be categorized as a game of skill, the element of chance would need to play little or no part in determining the outcome.
Additionally, the definition of 'game of chance' in the RGA is similar to the definition used in the UK's Gambling Act 2005, and there has been case law in the UK (R v Kelly  EWCA Crim 137) explaining that 'games of combined skill and chance' shall be treated as games of chance without qualification, except in circumstances where the element of chance was so insignificant as not to matter.