IN THE HIGH COURT OF THE REPUBLIC OF SINGAPORE 

Suit No. 182 of 1997

Between

LEE KUAN YEW
(NRIC No. S0000003E)


.. Plaintiff

and

1. TANG LIANG HONG
(NRIC No. 1096110F)

2. TEO SIEW HAR
(NRIC No. 0531156Z)

.. Defendants



DEFENCE OF THE FIRST DEFENDANT

1. The First Defendant contends that this suit, along with Suit Nos. 2523, 2524, and 2525 of 1996 and Suit Nos. 70, 76, 82, 172, 181, 187, 188 and 244 of 1997 ("the related actions") is an abuse of the process of the Court and should be struck out or stayed. This Defence is served without prejudice to that contention.

2. Paragraphs 1 and 2 of the Statement of Claim are admitted.

3. Paragraph 3 of the Statement of Claim is admitted, save that it is denied that the words spoken by the First Defendant were defamatory.

4. Paragraphs 4 and 5 of the Statement of Claim are admitted.

5. The First Defendant admits that he is responsible in law for the republication in the Straits Times of the words admittedly spoken by him. In all other respects, paragraph 6 of the Statement of Claim is denied.

6. It is denied that the words spoken by the First Defendant bore the meanings alleged in paragraph 7 of the Statement of Claim.

7. Paragraphs 8 and 9 of the Statement of Claim are denied.

8. Paragraph 10 of the Statement of Claim is not admitted.

9. Paragraph 11 of the Statement of Claims is admitted.

10. It is denied that the Plaintiff is entitled to aggravated damages whether by reason of the matters particularised in paragraph
12 of the Statement of Claim or at all. Paragraph 12 of the Statement of Claim is denied.

11. Without prejudice to the generality of the denial in paragraph 7 herein, the First Defendant will contend that paragraph 12(5) of the Statement of Claim discloses no entitlement to aggravated damages becuase there is no allegation that these matters caused injury to the Plaintiff.

12. Save as herein expressly admitted or averred, every allegation in the Statement of Claim is denied.

Dated this 21st day of February, 1997.



__________________________

Solicitors for the First Defendant

To the abovenamed Plaintiff

and his solicitors,

M/s Drew & Napier.

IN THE HIGH COURT OF THE REPUBLIC OF SINGAPORE

Suit No. 182 of 1997

Between

LEE KUAN YEW
(NRIC No. S0000003E)

.. Plaintiff

and

1. TANG LIANG HONG
(NRIC No. 1096110F)

2. TEO SIEW HAR
(NRIC No. 0531156Z)

.. Defendants

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DEFENCE OF THE FIRST DEFENDANT

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TANG & COMPANY

ADVOCATES & SOLICITORS

NO. 1 COLOMBO COURT #09-22

SINGAPORE 179742

TEL: 3372371

FAX: 3372035

Filed this 21st day of February, 1997