Lee Hsien Loong v Leong Sze Hian (g) [2021] SGHC 66 The presence of malice. The plaintiff argues that every one of these factors is relevant on the instant facts in warranting a significant award of damages. The plaintiff also argues that another consideration relevant to the determination of the quantum of general damages is its intended deterrent effect: The Gleaner Co Ltd v Abrahams [2004] 1 AC 628 at [53], as approved at [8] of Lim Eng Hock Peter. 86 The defendant argues on the other hand that only nominal damages should be awarded. The libel was not serious, less believable because it was on social media, and did not originate from the defendant. Rather, it was only shared by him. Moreover, mitigation occurred, which reduced any effect of the defamatory words. It was also contended that there was very limited evidence of publication of the Post and none of the Article. Even if there was any such evidence, the defendant argued that the publication level was very low. It was further said that no malice was made out, nor was it properly pleaded. In addition, while the defendant did not apologise, he removed the post upon receiving the IMDA notice, had not repeated the libels, and had not defended the statements made as true. 87 While different cases were cited by the parties as authority, the specific factors going towards quantum were not in dispute. Given my findings above that the Post and Article were each published, and that the latter could in fact be seen as part of the former (see above at [42]), the consequences of such publication will be taken together. The plaintiff’s reputation 88 In the present case, a particularly significant factor in determining the precise quantum of damages is the effect of the defamatory words on the 48

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