Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 published on the “public” setting, meaning that even individuals who were not friends of the defendant on Facebook could access it. 71 The third point I make above segues appropriately into the broader point I make in relation to Jameel, which is that even if the approach in Jameel were to be applied wholesale in Singapore law, it is not applicable to the current factual matrix. In Jameel, like Qingdao Bohai, very few individuals were found to have accessed the allegedly defamatory material. In the entirety of the English Court’s jurisdiction, the claimant could only point to five persons who had accessed the defamatory material, and three of those five persons were associated with the claimant himself. This paucity of individuals who had accessed the defamatory material is markedly absent on the instant facts. To illustrate the thrust of the mischief which the rule in Jameel seeks to address, the following extract is apposite: 69 If the claimant succeeds in this action and is awarded a small amount of damages, it can perhaps be said that he will have achieved vindication for the damage done to his reputation in this country, but both the damage and the vindication will be minimal. The cost of the exercise will have been out of all proportion to what has been achieved. The game will not merely not have been worth the candle, it will not have been worth the wick. 70 … It would be an abuse of process to continue to commit the resources of the English court, including substantial judge and possibly jury time, to an action where so little is now seen to be at stake. Normally where a small claim is brought, it will be dealt with by a proportionate small claims procedure. Such a course is not available in an action for defamation where, although the claim is small, the issues are complex and subject to special procedure under the CPR. I am not satisfied that the present claim is one “where so little … is at stake”. As has been accepted in Lee Kuan Yew v Seow Khee Leng [1988] 2 SLR(R) 252 (“Seow Khee Leng”) at [25] and Lee Kuan Yew and another v Vinocur John and others and another suit [1995] 3 SLR(R) 38 (“Vinocur John”) at [55], 39