De Souza Tay & Goh v Singapore Press Holdings: Defamation Claim over Article on L&H
De Souza Tay & Goh, a law firm, sued Singapore Press Holdings Ltd and a journalist for libel over an article published in The Straits Times that allegedly linked the firm to the suspected illegal activities of Lernout & Hauspie (L&H). The High Court dismissed the firm's claim, finding that the article was not defamatory in its natural and ordinary meaning or in its innuendo meaning. The plaintiffs appealed the decision, but the appeals were dismissed.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Appeals dismissed.
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Defamation claim by De Souza Tay & Goh against Singapore Press Holdings over an article linking them to suspected illegal activities of Lernout & Hauspie. Appeal dismissed.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Singapore Press Holdings Ltd. | Defendant | Corporation | Claim Dismissed | Won | |
| De Souza Tay & Goh (suing as a firm) | Plaintiff | Partnership | Appeals dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Lee Seiu Kin | Judicial Commissioner | Yes |
4. Counsels
4. Facts
- The plaintiffs are a law firm.
- The defendants published an article in The Straits Times about Lernout & Hauspie (L&H) and its licensees.
- The article mentioned that 15 Singapore-registered companies shared a common address in the plaintiffs' office.
- The plaintiffs claimed the article was defamatory, suggesting a link between them and L&H's suspected illegal activities.
- The High Court disagreed, finding the article not defamatory in its natural and ordinary meaning or innuendo meaning.
5. Formal Citations
- De Souza Tay & Goh (suing as a firm) v Singapore Press Holdings Ltd and another action, Suit 858/2000, 859/2000, RA 24/2001, 23/2001, [2001] SGHC 134
6. Timeline
| Date | Event |
|---|---|
| The Straits Times published an article about Lernout & Hauspie (L&H) and its licensees. | |
| The Straits Times published the Article which is the subject of the defamation claim. | |
| The plaintiffs filed applications for determination of the natural and ordinary meaning and the innuendo meaning of the Article. | |
| High Court dismissed the plaintiffs' claim. Appeals dismissed. |
7. Legal Issues
- Defamation
- Outcome: The court held that the article was not defamatory in its natural and ordinary meaning or in its innuendo meaning.
- Category: Substantive
- Sub-Issues:
- Natural and ordinary meaning
- Innuendo meaning
8. Remedies Sought
- Damages
9. Cause of Actions
- Defamation
- Libel
10. Practice Areas
- Litigation
11. Industries
- Media
- Legal
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Microsoft Corp v SM Summit Holdings | Court of Appeal | Yes | [1999] 4 SLR 529 | Singapore | Cited for the general principles pertaining to the determination of the natural and ordinary meaning of words in a defamation action. |
| Jeyaretnam Joshua Benjamin v Goh Chok Tong | N/A | Yes | [1984-1985] SLR 516 | N/A | Cited for the principle that the court decides the meaning of words based on how an ordinary, reasonable person would understand them. |
| Jeyaretnam Joshua Benjamin v Goh Chok Tong | N/A | Yes | [1985] 1 MLJ 334 | N/A | Cited for the principle that the court decides the meaning of words based on how an ordinary, reasonable person would understand them. |
| Jeyaretnam Joshua Benjamin v Lee Kuan Yew | N/A | Yes | Jeyaretnam Joshua Benjamin v Lee Kuan Yew | N/A | Cited for the principle that the court decides the meaning of words based on how an ordinary, reasonable person would understand them. |
| Rubber Improvement Ltd v Daily Telegraph Ltd | N/A | Yes | [1964] AC 234 | N/A | Cited for the principle that the natural and ordinary meaning of words includes inferences drawn by the ordinary man. |
| Goh Chok Tong v Jeyaretnam Joshua Benjamin and another action | N/A | Yes | [1998] 3 SLR 337 | Singapore | Cited for the relevance of considering observations made in Skuse v Granada Television Ltd when drawing inferences. |
| Skuse v Granada Television Ltd | English Court of Appeal | Yes | [1996] EMLR 278 | England and Wales | Cited for the characteristics of the hypothetical reasonable reader or viewer in defamation cases. |
| Slim v Daily Telegraph Ltd | N/A | Yes | [1968] 2 QB 157 | N/A | Cited for cautioning against over-elaborate analysis of the material in issue. |
| Lewis v Daily Telegraph | N/A | Yes | [1964] AC 234 | N/A | Cited for the principle that a statement that a person is under investigation is not capable of meaning that such person is guilty of the crime being investigated, but it may bear the defamatory meaning that the person is under suspicion or that there are reasonable grounds for suspicion |
| Lewis v Daily Telegraph | N/A | Yes | [1963] 2 All ER 151 | N/A | Cited for the principle that a statement that a person is under investigation is not capable of meaning that such person is guilty of the crime being investigated, but it may bear the defamatory meaning that the person is under suspicion or that there are reasonable grounds for suspicion |
| Charleston v News Group Newspapers | House of Lords | Yes | [1995] 2 AC 65 | United Kingdom | Cited for the principle that a plaintiff cannot select an isolated passage in an article and complain of that alone if other parts of the article throw a different light on that passage. |
| Charleston v News Group Newspapers | House of Lords | Yes | [1995] 2 All ER 313 | United Kingdom | Cited for the principle that a plaintiff cannot select an isolated passage in an article and complain of that alone if other parts of the article throw a different light on that passage. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| No applicable statutes | |
15. Key Terms and Keywords
15.1 Key Terms
- Defamation
- Libel
- Natural and ordinary meaning
- Innuendo
- Lernout & Hauspie
- Singapore Press Holdings
- The Straits Times
15.2 Keywords
- defamation
- libel
- Singapore Press Holdings
- De Souza Tay & Goh
- Lernout & Hauspie
- High Court
- Singapore
- media law
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Defamation | 95 |
| Fraud and Deceit | 60 |
| Contract Law | 10 |
16. Subjects
- Defamation
- Media Law