Lee Hsien Loong v Leong Sze Hian 35 [2021] SGHC 66 Implicit in the defendant’s position on the Article, however, is a recognition that had individuals clicked on the Article as a result of his sharing the Post, he would be responsible for publication of the Article. Put another way, the defendant does not appear to deny that providing a hyperlink to a separate article in a post can, in principle, be a basis for a finding that there has been publication of that article. 36 On the facts of this case, I find that there has been publication by the defendant of the Post. The defendant has conceded as much. The issue of how substantial the publication was will be dealt with subsequently, when I consider the question of quantum (see below from [92] to [106]). For the moment, it suffices for me to note the view of Belinda Ang J (as she then was) in Qingdao Bohai Construction Group Co, Ltd and others v Goh Teck Beng and another [2016] 4 SLR 977 (“Qingdao Bohai”) at [61] and [136] that “substantial” publication simply refers to publication to a “sufficient number [of readers] to justify judgment for damages”. This, I should add, simply means that there must have been a real and substantial tort, and that the publication must not be, in effect, de minimis. As I will go on to explain, the instant publication can hardly be said to not have been substantial in Singapore. 37 As for the Article, I also find that it has been published by the defendant. This arises on two bases: First, because the Article is part of the Post, by virtue of having been hyperlinked from the Post. Second, because the Article itself has been published because the defendant has made it accessible, and individuals within Singapore have, through his link, accessed it. In my view, there is a platform of facts which suffices for me to rely on either of those two bases to conclude that there has been publication of the Article. 19