DANIEL MAAG & Anor v LALIT KUMAR MODI

[2024] SGHC 311 High Court (General Division) 5 December 2024 • HC/OC 660/2023 ( HC/RA 77/2024 ) • 100 min read
31 cases cited (20 SG, 11 foreign)

Outcome

Appeal allowed

I thus allow the appeal in part and award Mr Modi costs here and below.

Source: [2024] SGHC 311, High Court (General Division), decided 5 December 2024. Read directly from the judgment.

Key facts

Court High Court (General Division)
Decided
Judge Dedar Singh Gill
Charges / claim Tort, Conflict of Laws, Civil Procedure
Outcome Appeal allowed
Counsel Eugene Thuraisingam LLP, Providence Law Asia LLC, Abraham Vergis, Hamza Zafar Malik, Hari Veluri, Suang Wijaya, Timothy Hew Zhao Yi

Source: [2024] SGHC 311, High Court (General Division), decided — eLitigation. Updated .

Catchwords

Practice Areas

Judges (1)

Counsel (7)

Parties (3)

Case Significance

Maag, Daniel and another v Lalit Kumar Modi [2024] SGHC 311 is a reserved judgment of the General Division of the High Court delivered on 5 December 2024 by Dedar Singh Gill J in Originating Claim No 660 of 2023 (Registrar's Appeal No 77 of 2024). The defendant, Mr Lalit Kumar Modi (whom the claimants aver is an Indian national), appealed against the Assistant Registrar's decision allowing the claimants, Daniel Maag and Gurpreet Gill Maag, to amend their statement of claim. It was common ground that Mr Modi ran a page on the platform "X" with 3.8 million followers and an Instagram page with 5.2 million followers at the material time. The judgment addresses tort of defamation and malicious falsehood, conflict of laws and jurisdiction, service out of jurisdiction, and amendment of pleadings.

Summary

Daniel Maag and Gurpreet Gill Maag, who are based in Singapore, sued Lalit Kumar Modi in the General Division of the High Court over a social media post (the 'Litigation Post') they alleged contained malicious falsehoods and defamatory material; Mr Modi appealed against an assistant registrar's decision allowing the Maags to amend their statement of claim. The appeal engaged issues of defamation and malicious falsehood, publication, service out of jurisdiction, conflict of laws jurisdiction, and the principles for amending pleadings. Dedar Singh Gill J allowed the appeal in part, permitting certain amendments while disallowing others, and awarded the defendant costs here and below.

What was Maag, Daniel v Lalit Kumar Modi [2024] SGHC 311 about?

In [2024] SGHC 311, Dedar Singh Gill J heard Lalit Kumar Modi's appeal against an Assistant Registrar's decision allowing claimants Daniel Maag and Gurpreet Gill Maag to amend their statement of claim, in a dispute involving defamation, malicious falsehood, jurisdiction and service out of jurisdiction.

What social media following did the defendant have in Maag v Lalit Kumar Modi ([2024] SGHC 311)?

Per [2024] SGHC 311, it was common ground that the defendant, Mr Lalit Kumar Modi, ran a page on the platform "X" with 3.8 million followers and an Instagram page with 5.2 million followers at the material time, relevant to the claims of defamation and malicious falsehood.

Statutes Cited

s 6(1) s 6(1)(b) s 8
UK Defamation Act
s 1 s 1(1) s 8 s 8(4)

Cases Cited (31)

SG (2)
[2016] SGHCR 6 [2018] SGHC 123
SLR (18)
[1997] 3 SLR(R) 46 [2000] 1 SLR(R) 53 [2007] 2 SLR(R) 453 [2008] 4 SLR(R) 727 [2009] 1 SLR(R) 642 [2012] 4 SLR 546 [2014] 1 SLR 639 [2015] 1 SLR 797 [2015] 2 SLR 751 [2016] 4 SLR 977 [2018] 3 SLR 117 [2019] 5 SLR 366 [2020] 1 SLR 327 [2022] 2 SLR 1018 [2023] 3 SLR 1191 [2024] 1 SLR 419 [2024] 4 SLR 540 [2024] 4 SLR 907
UK (9)
[2000] 1 WLR 1004 [2005] QB 946 [2006] 3 WLR 642 [2008] EWHC 2636 [2013] EWHC 3540 [2021] 3 WLR 1011 [2022] EWHC 1535 [2023] 3 WLR 167 [2024] 3 WLR 153
AU (1)
[2008] NSWSC 669
HK (1)
[2022] 5 HKC 426

Related cases

Other Singapore judgments involving the same parties or counsel.

Referenced in

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2024] SGHC 311)