Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 The doctrine in Jameel 66 In Jameel, the English Court of Appeal concluded that, as there had been no real and substantial tort committed within England, it was an abuse of process for the plaintiff in that case to pursue his claim. In Jameel, a foreign claimant commenced proceedings for defamation in England against the publisher of an American newspaper in respect of an article posted on a website in America. The publisher, in response, adduced evidence which showed that only five persons in the jurisdiction of the English courts had accessed the website, of whom three were associates of the plaintiff. The publisher thus applied to strike out the claim on the ground that it had no reasonable prospect of success. In upholding the decision to strike out the claim, the English Court of Appeal held that no real and substantial tort had been committed within the jurisdiction, and that it would be an abuse of process for the plaintiff to be permitted to proceed with his claim. This was despite the publisher not having previously objected to the jurisdiction of the English courts on the basis of forum non conveniens. The English Court of Appeal specifically observed that even if the plaintiff succeeded, the vindication it received would be minimal and the cost of the entire suit would have been out of proportion to what had been achieved. 67 I have some difficulty with the conclusion the defendant invites me to draw from Jameel, that the case applies wholesale to the instant facts to render the plaintiff’s claim an abuse of process. First, it appears to me that the decision in Jameel was animated in large part by developments unique to the United Kingdom, and which find no ready parallel in Singapore. The application of the reasoning and principles in Jameel to the Singapore context thus must be highly fact-specific, and a broad-brush approach to applying Jameel does not appear 34