Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 at least some aggravation arising from the defendant’s conduct, though perhaps not nearly as much as the plaintiff sought to persuade me of. 116 In sum, while I accept that there has been aggravation on the instant facts, I do not consider that the allegedly aggravating conduct went so far as to attract a markedly increased award of damages. In particular, the defendant’s supposed drawing of attention to the statement had been done in the midst of explaining his position, and I am satisfied that the quantum of aggravated damages on these facts should be calibrated to reflect that. Malice 117 The Plaintiff argues that malice is made out on the facts. As the Court in Lee Kuan Yew v Davies Derek Gwyn and others [1989] 2 SLR(R) 544 at [112] observed, malice in defamation refers to any “ill-will, spite, or some wrong or improper motive”. It is also generally accepted that malice may be inferred if it is abundantly plain that the defamatory statement is untrue: Mangena v Edward Lloyd Ltd (1908) LT 640 at 643. As is made clear in Richard Parkes QC et al, Gatley on Libel and Slander (Sweet & Maxwell, 12th Ed, 2017) at [32.45], malice may be inferred from the defendant’s conduct at any time, whether before or after the publication, his actions during the course of litigation, and his demeanour and attitude at trial. In this regard, the plaintiff points to three categories of behaviour it alleges make out malice on the instant facts: (a) First, the defendant’s conduct in publishing the defamatory words while knowing them to be untrue or recklessly not caring whether they are true or not; (b) Second, the defendant’s alleged conduct in using the suit to wage a public campaign to gain sympathy and support; and 63