Constitutionalism in Asia in the Early Twenty-First Century

(Greg DeLong) #1

court was necessarily contemptuous. He recognised the ‘powerful public interest’


in ‘exposing and rooting out impropriety and corruption’ by those holding public


office,^154 which the Court of Appeal affirmed.^155


While questioning whether fair criticism was a defence against or element of


liability, the Court of Appeal inShadrake 2 recognised that scandalising contempt


should not stifle fair, reasonable criticism, referring to a series of Commonwealth


cases which emphasised the ‘right’ of fair criticism.^156 This right is a welcome change


from a prior reticence towards affirming free-speech values. In addition, it endorsed


the utility of the guidelines on fair criticism articulated inTan Joo Liang.^157


political defamation.Singapore case law on political defamation has attracted


much criticism for unduly chilling free speech critical of political actors and


institutions, through the award of astronomically high damages, rejecting a


public-figure doctrine and underprotecting free speech, in contrast to highly valued


reputational rights. In this context, the free-speech rationale rests on the role of


robust and free debate within democratic societies.


There were a spate of cases relating to political libel in the first decade, and


extensive consideration of Commonwealth decisions from the United Kingdom,


New Zealand and Australia. In 1993 the Court of Appeal inJB Jeyaretnamv.Lee


Kuan Yew
158
rejected the ‘actual-malice’ test inNew York Timesv.Sullivan
159
and the


‘public-figure’, doctrine which requires a politician to have a thicker skin when it


comes to criticism, because of the public interest involved. The fear was that the


insufficient protection of reputation would deter honourable and sensitive men from


entering politics, to the public detriment. This public good outweighed the public


good of free speech in a democracy in relation to speech critical of politicians.


Notably the courts, in balancing competing interests, have begun to develop a


theory of reputational rights. Judge Ang inLee Hsien Loongv.SDP^160 underscored


the importance of reputation, a non-constitutional interest, noting that defamation


law ‘presumes the good reputation of the plaintiff’. Ang J quoted the Greek


rhetorician Isocrates, who noted that ‘the stronger a man’s desire to persuade his


hearers, the more zealously will he strive to be honourable and to have the esteem


of his fellow citizens’.^161


Singapore has adopted a public-figure doctrine of sorts, but one that does not


require toleration of more criticism. InTang Liang Hongv.Lee Kuan Yew,^162


the court rejected the argument that damages awarded against an opposition


politician, who was sued by thirteen members of the PAP government, should be


reduced where the successful plaintiff is a politician or the case has a political


flavour. Thean JA argued that this was ‘untenable and wrong’ as it would ‘allow a


(^154) Shadrake 1 ,[ 76 ]. (^155) Shadrake 2 ,[ 84 ]. (^156) Shadrake 2 ,[ 65 ]–[ 66 ].
(^157) Shadrake 2 ,[ 81 ]–[ 82 ]. (^158) [ 1990 ] 2 MLJ 65. (^159) ( 1964 ) 376 US 254.
(^160) [ 2009 ] 1 SLR 642 ,[ 102 ]. (^161) [ 2009 ] 1 SLR 642 ,[ 102 ]. (^162) [ 1998 ] 1 SLR 97.


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