Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 publication from potentially being defamatory without closer examination on the facts of what a bare hyperlink, with no added commentary, might convey in all the circumstances. A more holistic assessment should be preferred, and it is for that reason that I find the English and Australian cases I have cited above to be of greater utility on the facts. A fact-centric analysis should be pursued. 42 Considering the relevant facts and circumstances, I am satisfied that the Article should be construed as part of the Post for the following reasons: (a) First, the link to the Article was the only substantive content of the Post. Apart from the link, the only other content in the Post was an extract of the text of the Article’s title, and a photo from the Article. The entire content of the Post was, in effect, the Article, and it would be artificial to draw a bright-line distinction between the two. (b) Second, there does not appear to be any other plausible interpretation of the link to the Article in the Post apart from the defendant in some way supporting or endorsing the content in the link. The entirety of his message in the Post centred around the link to the Article, and he was at the very least drawing attention to the Article and providing access to it in the Post. Further, an interpretation that the defendant was endorsing the content of the Article would cohere with his own self-described role as a “staunch government critic”.21 This descriptor is present on, inter alia, the defendant’s own website. (c) Third, as alluded to at [19] above, one effect of the defendant’s submission of no case to answer is that the plaintiff does not need to 21 Transcript of 6 October 2020, Page 80 at Line 14; Page 120 at Line 24; Page 124 at Lines 19 to 20; Page 135 at Line 5; Page 138 at Line 9; and Page 154, Line 25 to Page 155, Line 1. 22