STEPHEN TAN HOCK SAN v CHAN YEOK PHENG & Anor

STEPHEN TAN HOCK SAN v CHAN YEOK PHENG & Anor

The claim is dismissed because the Claimant failed to prove that either Defendant was responsible for publishing the impugned documents; the evidence did not establish a sufficient link between the Defendants and the distributors and the Defendants' denials were not credibly undermined such that publication could be inferred, and any adverse inference would only reduce weight of testimony rather than substitute proof of publication.

Citation
[2026] SGMC 1
Parties
Claimant: Stephen Tan Hock San; First Defendant: Chan Yeok Pheng; Second Defendant: Kelvin Toi Hao Yuan (Tian Haoyuan)
Court
Magistrates' Court
Jurisdiction
Singapore
Judgment Date
27 January 2026
Case Number
MC/OC 6027/2024
Procedural Posture
Defamation (tort) Magistrates' Court Originating Claim No 6027 of 2024 / Judgment Delivered 27 January 2026
Outcome
Claim dismissed against both Defendants
Legal Topics
Publication, Justification, Qualified Privilege, Fair Comment, Proof of Publication, Adverse Inference, Burden of Proof, Similar Fact Evidence
Source Language
English
Tort Defamation Evidence Civil Procedure Corporate/management Disputes Publication Justification Qualified Privilege +5 more

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Parties

Stephen Tan Hock San

Claimant

Chan Yeok Pheng

First Defendant

Kelvin Toi Hao Yuan (Tian Haoyuan)

Second Defendant

Procedural Posture

Defamation (tort) Magistrates' Court Originating Claim No 6027 of 2024 / Judgment Delivered 27 January 2026

Legal Issues

  1. 1 Whether the First and/or Second Defendant published the impugned statements
  2. 2 Whether publication was proved by direct or sufficient circumstantial evidence
  3. 3 Whether adverse inferences should be drawn for alleged withholding of documents under s 116 illus (g) Evidence Act 1893

Ratio Decidendi

The claim is dismissed because the Claimant failed to prove that either Defendant was responsible for publishing the impugned documents; the evidence did not establish a sufficient link between the Defendants and the distributors and the Defendants' denials were not credibly undermined such that publication could be inferred, and any adverse inference would only reduce weight of testimony rather than substitute proof of publication.

Court Disposition

Claim dismissed against both Defendants

Orders

  • Parties to file and exchange written submissions on costs (limited to 7 pages) within 14 days from date of this judgment