Lee Hsien Loong v Leong Sze Hian (c) [2021] SGHC 66 Third, the defendant’s failure to make any sufficient apology or withdrawal of the defamatory words. As is readily apparent, items (b) and (c) are simply restatements of arguments the plaintiff had relied on in relation to the question of whether the defendant’s conduct was aggravating. Accordingly, I will focus on item (a) instead. Before that, however, I consider two preliminary objections by the defendant to allegations of malice. 118 First, the defendant alleged that malice had not been properly pleaded. I am unable to agree. I note that the Statement of Claim averred various matters, including statements from politicians, government agencies, and press reports which all stated categorically that the content in the Article was false, and that action was being taken: Statement of Claim from [3(l)] to [3(n)]. These averments were also the foundation of the claim for aggravated damages. Given the plain wording of these averments, which went towards suggesting that the defendant was aware of the false nature of the defamatory words from an early stage, no further pleading was required. 119 Second, the defendant appears to suggest, by referring to conduct that is “tantamount to dishonesty” in his submissions,51 that dishonesty is required in order to establish malice in the context of defamation. If this is the defendant’s suggestion, it is incorrect given the clear authority of Goh Chok Tong v Jeyaretnam Joshua Benjamin and another [1998] 2 SLR(R) 971 at [53]. 120 In relation to the plaintiff’s claim that the defendant had published the defamatory words while knowing them to be untrue or recklessly not caring 51 DCS at [126]. 64