Lee Hsien Loong v Leong Sze Hian 38 [2021] SGHC 66 Turning to the first basis for finding that the Article has been published by the defendant, the reasoning is fairly straightforward: insofar as the Article forms part of the Post, and the Post has itself been published, the Article (and its content) can be said to have been published as well. 39 Support for this proposition may be drawn from the view of Nicklin J in Daniel Poulter MP v Times Newspapers Limited [2018] 3900 QB (“Poulter”) at [21]: The position seems to me to be different in relation to the online publication. I noted in Falter v Altzmon [2018] EWHC 1728 QB that the rule from Charleston that readers are taken to read the whole of a publication has its limits in relation to links provided in an online version of an article: [12] The Internet provides a degree of challenge to [the] orthodoxy [of Charleston] because it is possible to set out in on-line publications many hyperlinks to external material. It is perhaps unrealistic to proceed on the basis that every reader will follow all the hyperlinks, but everything depends on its context. For example, if in a single tweet there is a single statement that says, “X is a liar” and then a hyperlink is given, it is almost an irresistible inference to conclude that the ordinary reasonable reader would have to follow the hyperlink in order to make sense of what was being said. At the other end of the spectrum, a very long article could contain a very large number of hyperlinks. Only the most tenacious or diligent reader could be expected to follow every single one of those hyperlinks. Such a reader could hardly be described as the ordinary reasonable reader. How many links any individual reader would follow would depend on an individual’s interest in or knowledge of the subject matter or perhaps other particular reasons for investigating each of the hyperlinks in question. Of particular note from this extract is the view that if only a single statement is made, and one hyperlink given, it is “almost an irresistible inference” to conclude that the ordinary reasonable reader would follow the hyperlink, thus triggering the rule in Charleston v News Group Newspapers Ltd [1995] 2 AC 20

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