Lee Hsien Loong v Leong Sze Hian 68 [2021] SGHC 66 Of course, that is not to say that the principles outlined in Jameel are of no value in Singapore. Notably, the Court of Appeal made the following observations on Jameel at [120] of Yan Jun v Attorney-General [2015] 1 SLR 752 (“Yan Jun”): … In light of our decision above at [111]–[114], it is, strictly speaking, not necessary for us to decide whether the Judge was correct in following Jameel. That having been said, there is a relatively significant body of authority in England endorsing the general principle established in Jameel, viz, that a claim which discloses no real and substantial tort is liable to be struck out for being an abuse of process of the court, and the real concerns (as we have seen above) relate to its application. This lastmentioned point is not surprising in view of the fact that the line-drawing required is not only fact-centric but may also be difficult to effect in borderline situations. Further, and leaving aside the differences in the rules of civil procedure between England and Singapore, Jameel also contains some general principles that may be applicable in the Singapore context. Hence, applying the principle in Jameel to the facts of the present case, we would be of the view that this was far from being a borderline situation and that the Judge was therefore correct in following and applying Jameel and holding that the Appellant’s claim in defamation did not disclose a real and substantial tort. This would have served as a yet further reason as to why the Appellant’s claim in defamation should fail. [Emphasis original] The upshot of this extract is twofold: First, there remain “real concerns” with the precise application of Jameel, which must be highly fact-centric, though certain general principles may be applicable to the Singapore context. Second, the discussion of Jameel in Yan Jun proceeded on the basis that the facts in Yan Jun did not disclose a “borderline” situation. Instead, it was clear in that case that the claim for defamation in Yan Jun was not only wholly untenable, but also that even if the claim had succeeded, any vindication received would be out of all proportion to the cost of procuring it. The reasoning in Jameel was merely a “yet further” (emphasis original) reason as to why the claim should fail. 36