Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 establish an irresistible inference that the Article was part of the Post. All that is required is for the plaintiff to show that the desired inference is one of the possible inferences. 43 In addition, I note two Singaporean decisions pertaining to when publication online suffices as publication for the purposes of defamation. In both Qingdao Bohai at [35] and Golden Season Pte Ltd and others v Kairos Singapore Holdings Pte Ltd and another [2015] 2 SLR 751 (“Golden Season”) at [54], the High Court held that publication by the defendant occurred if (a) the defamatory statements were made available online, and (b) the defamatory material was received by a third party in such a way that it is understood and intelligible. (The related but separate question of where such publication occurred is determined by where the reader or end user accesses the statement: Ng Koo Kay Benedict at [26]). This implies that a Facebook post which carries a link, and which makes the defamatory statement available, would count as a publication if it could be established that third parties had accessed that link. In contrast, and subject of course to the precise facts, a hypothetical Facebook post that merely referred or alerted other users to the existence of the original defamatory statement, without carrying a link, might not count as publication. I do note that it is perhaps easier for a Facebook user to post or a share a link to the original statement than to compose and type out an entirely new statement alerting others to the original, but such ease of posting or sharing cannot rescue a post from being publication for the purposes of defamation. 44 The decisions in Qingdao Bohai and Golden Season are decisions of coordinate jurisdiction, and therefore not binding on me. But, with respect, their approach is sound in principle. Given that it is common ground that the defendant did make the Article available online by linking to it in the Post (thus satisfying the first requirement set out in Qingdao Bohai and Golden Season), 23

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