Prior to the second world war, Bugis had a high proportion of Japanese prostitutes; Karayuki-san. At its peak, there were 633 Karauki-san to 109 brothels, with a high concentration within the area of Bugis Street, Malabar Street, and Hylam Street. Due to the lack of space in the early-style, two storey, shophouse, overcrowding and hygiene issues became problematic. With many people using the same latrines and drinking water sources, disease spread with a cholera outbreak occurring in Bugis, Malabar, and Hylam Streets. This led to them being zoned off. The bad hygiene and poor ventilation due to overcrowding of the sites led to the Singapore Improvement Trust trying to demolish those buildings and rebuild. This led to the infamous "Bugis Street Case" which over the course of multiple courts decisions, decided that it was not legal to commandeer a building and only pay the price of the land, which had been going on previously and the decision was made by 1937, that new houses should be built to alleviate overcrowding and problems that are associated instead of tearing it down and rebuilding, expecting change to occur. This established a new form of slum clearance in Singapore that was more closely tied to the rights of the citizen and the owner.