Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 included the defendant’s counsel’s conduct when conducting his crossexamination of the plaintiff. (c) Third, the plaintiff highlighted that the defendant had failed to make any sufficient apology or withdrawal of the defamatory words. The plaintiff relied on Arul Chandran at [55] and Koh Sin Chong Freddie at [51] as authority for the proposition that the above acts would aggravate the injury inflicted by the defendant. 111 I note the observations of Lee Seiu Kin J in Lee Hsien Loong v Ngerng Yi Ling Roy [2016] 1 SLR 1321 (“Roy Ngerng”) from [84] to [86] in relation to the nexus the defendant’s subsequent conduct must have to the original defamatory statement. Lee J recognised the appeal of the position in England as set out in Collins Stewart Ltd v The Financial Times Ltd [2006] EMLR 5 at [24] to [27], that the subsequent conduct must have aggravated the injury arising from the defamation for which the defendant has been sued in order for it to constitute an aggravating factor. However, Lee J concluded that this position was inconsistent with the approach taken by F A Chua J in Lee Kuan Yew v Jeyaretnam Joshua Benjamin [1979–1980] SLR(R) 24 that casting aspersions over a plaintiff’s motives in the defamation action would in and of itself constitute an aggravating factor. As Chua J’s decision was upheld on this point on appeal in Jeyaretnam Joshua Benjamin v Lee Kuan Yew [1979–1980] SLR(R) 255 at [17], Lee J found himself “constrained” to find, on the authority of the Court of Appeal’s decision, that the defendant’s acts were aggravating. 112 I have considerable sympathy for Lee J’s view. It would be difficult for the Court to form a view as to the defendant’s subsequent conduct, if actionable in itself, without a proper consideration of all relevant matters, including any 60