Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 allegations of corruption and criminal conduct are “very grave charges”, especially when made against the Prime Minister of a country. Such allegations are an “attack on the very core of [his] political credo” and erode his “moral authority”. As I observed at [53] of my decision in SUM 428, these grave allegations may mar the Prime Minister’s reputation even if they are published to only a small number of individuals. In any event, publication in this case was not only to a small number of individuals (see [92] to [106] below). I am accordingly unconvinced that Jameel is applicable to the present facts. 72 The decision in Lait v Evening Standard [2011] 1 WLR 2973 (“Lait”) was also referred to in argument before me, with the defendant arguing that it illustrates that Jameel extends beyond any basis in the civil procedure rules and is concerned with balancing the private right of reputation and the public interest in freedom of expression. Support for this proposition is said to derive from [41] and [45] of Lait: 41 … The principle identified in the Jameel case consists in the need to put a stop to defamation proceedings that do not serve the legitimate purpose of protecting the claimant’s reputation. Such proceedings are an abuse of process. The focus in the cases has been on the value of the claim to the claimant; but the principle is not, in my judgment, to be categorised merely as a variety of the de minimis rule tailored for defamation actions. Its engine is not only the overriding objective of the Civil Procedure Rules but also, in Lord Phillips MR’s words, the need to keep “a proper balance between the article 10 right of freedom of expression and the protection of individual reputation”. This will especially be so where a defence of honest comment is advanced by a responsible – I emphasise the adjective – journalist … Accordingly the balance to be struck between public interest and private right will be a material consideration when the court has to consider the application of the Jameel principle in a case where a responsible media defendant pleads honest comment. This conclusion is I think fortified by section 12(4)(a) of the Human Rights Act 1998 … 45 I do not consider that this approach … should be regarded as a radical step. The balance to be struck between public interest and private right is increasingly to be seen as a function 40