Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 specifically was said in a libel. At [46] of Chase, Brooke LJ traced the distinction in levels of meaning to Lord Devlin in Rubber Improvement Ltd and another v Daily Telegraph [1964] AC 234 at 282: I do not mean that ingenuity should be expended in devising and setting out different shades of meaning. Distinct meanings are what should be pleaded; and a reasonable test of distinctness would be whether the justification would be substantially different. In the present case, for example, there could have been three different categories of justification – proof of the fact of an inquiry, proof of reasonable grounds for it, and proof of guilt. Given that no plea of justification has been raised here, I could not see that reliance on Chase was useful in the analysis. In any event, I note the observation in Ng Koo Kay Benedict and another v Zim Integrated Shipping Services Ltd [2010] 2 SLR 860 (“Ng Koo Kay Benedict”) at [17] that “All three [Chase] levels are generally regarded as being defamatory, though in varying degrees”. At highest, therefore, the defendant appears to contend that the effect of the defamatory words was not particularly impactful. However, this is simply not borne out on the facts, particularly in relation to the Article. In the Article, specific allegations are made regarding the plaintiff’s corruption, notably in relation to the provision of Singapore banks’ assistance in laundering 1MDB funds. Moreover, as the defendant himself acknowledges, relying on Stocker v Stocker [2020] AC 593 from [41] to [46], a reader casually parsing a Facebook post adopts an impressionistic and fleeting response.18 He may not be entirely alive to the nuances of the Chase levels, and may instead only draw a loose and imprecise association between the wording of the Post and/or Article, and the criminality associated with 1MDB. Whatever the case, I do not find that the defendant can reasonably claim that the defamatory words did not impugn the 18 DCS at [20] to [22]. 17