Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 The defendant specifically emphasised that the above actions had been carried out by individuals or institutions of high public standing, in credible publications. Accordingly, it was contended that any harm caused by the defamatory words was neutralised or in some sense ameliorated. 62 These actions and speeches did not, to my mind, reduce the harm caused to the plaintiff’s reputation for the purposes of ascertaining if there had been damage suffered in the tort of defamation. First, the law of defamation does not require proof of actual damage to reputation: Tang Liang Hong v Lee Kuan Yew and another and other appeals [1997] 3 SLR(R) 576 from [110] to [112]. Rather, the concern is with the effect on right-thinking members of society: Sim v Stretch [1936] 2 All ER 1237 at 1240. The standard is notional or fictional; one does not conduct a survey of a selected group of persons to determine the effect of the defamatory words and the loss suffered. As long as it is reasonable that one’s reputation could be harmed, it does not matter if no one with such a view is in fact found and produced to the court. 63 The fact that there may be countervailing information provided or statements made does not reduce or negate a defamation, particularly when those statements or pieces of information do not even originate from the party which is responsible for the defamation. The focus of the analysis on the extent of the injury is on the effect of the alleged defamatory statement on the claimant’s reputation. It is clear following Goh Chok Tong v Jeyaretnam Joshua Benjamin [1997] 3 SLR(R) 46 at [50] and [84] that even if a defamatory imputation is so incredulous or outrageous that it would not be believed, such an imputation would still be defamatory. This was explained on the basis that if the incredulity of the imputation were a relevant consideration, it would lead to the ironic situation where an extremely outrageous statement would never be actionable simply because it was especially outrageous and unbelievable. The 32