Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 [1991] 1 SLR(R) 230 at [16]. As the plaintiff has argued, the Court in Lee Hsien Loong v Singapore Democratic Party [2007] 1 SLR 675 accepted that news reports could be considered in determining how widely known certain facts are, and thus how an ordinary reasonable person would identify the natural and ordinary meaning of the words used. Given the sheer volume of reporting on the issue, the facts surrounding the 1MDB episode cannot be said to go beyond the ordinary reasonable person’s general knowledge. Furthermore, the point of the extrinsic evidence rule is that reference to such extrinsic evidence may take the meaning of the allegedly defamatory words out of their natural and ordinary meaning, such that the meaning then would really be one of innuendo: Goh Chok Tong v Joshua Benjamin Jeyaretnam [1997] 3 SLR(R) 46 at [93] to [100]. A case founded on innuendo would have to be specifically pleaded. However, there is no evidence to suggest that the plaintiff is in fact relying on some covert innuendo meaning on the instant facts. As observed by the Court in Gordon Berkeley Jones v Clement John Skelton [1963] 1 WLR 1362 from 1370 to 1371, what counts as impermissible extrinsic fact for the purpose of the extrinsic evidence rule is something that goes beyond general knowledge. 31 There was also some argument between the parties about the Chase meanings as laid down in Chase v News Group Newspapers Ltd [2002] EWCA Civ 1772 (“Chase”) at [45].17 I am doubtful though that this was, in the end, useful. Such determination of meaning was considered in Chase in the context of determining what was to be put forward in a defence of justification. One must bring in sufficient evidence to show the truth of what was asserted, which must in turn be dependent on what exactly was asserted. This thus gave rise to the need to calibrate, by reference to the three levels of Chase meanings, what 17 See, for example, PCS at [54] et seq and Defendant’s Closing Submissions (“DCS”) at [23] et seq. 16

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