Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 65 that the material has to be read holistically and in full. It also bears note that the defendant himself relies on Poulter, and in fact on this specific extract at [21] of that case. 40 The instant facts, however, are not directly akin to the situation highlighted in Poulter, where an almost “irresistible inference” would be drawn. The main difference is that the defendant simply shared a link (with some of the text of the title of the linked Article shown), without any comment of his own. If there were some comment from the poster either endorsing or disparaging the linked remarks or the article, then the determination would be reasonably clear. But, if nothing else is appended, then whether the provision of the link amounts to a publication would have to be more carefully considered. 41 On one view, a bare link is all that it is: there is no publication, because all that is in fact published is the hyperlink, which on clicking, would bring the reader elsewhere. This would appear to be the position taken in Canada in the decision of the majority in Crookes v Newton [2011] 3 SCR 269. Specifically, Abella J (Binnie, LeBel, Charron, Rothstein, and Cromwell JJ concurring) held at [44] that “… in my view the use of a hyperlink cannot, by itself, amount to publication even if the hyperlink is followed and the defamatory content is accessed”. This somewhat absolute position was heavily influenced by the Canadian Charter of Rights and Freedoms, and has not been followed in both Australia (see for example, Bailey v Bottrill (No 2) [2019] ACTSC 167 at [54]) and England (see for example, Caine v Advertiser and Times Ltd & Ors [2019] EWHC 2278 (QB) at [61], relying on the decision of the European Court of Human Rights in Magyar Jeti Zrt v Hungary [2018] 12 WLUK 615 at [77]). In any event, I am not persuaded that Abella J’s position should be adopted in Singapore. It is not only predicated heavily on an instrument which does not have effect in Singapore, but more fundamentally, ousts an entire species of 21