Case Details
- Citation: [2025] SGDC 271
- Title: MAKERICKS3D LLP v Terence Lee Meng Kai
- Court: District Court (State Courts of the Republic of Singapore)
- Judgment Date: 13 October 2025
- Judges: District Judge Jonathan Ng Pang Ern
- District Court Originating Claim No: 374 of 2023
- Hearing Dates: 7, 8 July, 16 September 2025
- Judgment Reserved: Yes
- Plaintiff/Applicant: MAKERICKS3D LLP
- Defendant/Respondent: Terence Lee Meng Kai
- Legal Areas: Tort — Defamation; Tort — Malicious falsehood
- Statutes Referenced: Not stated in the provided extract
- Cases Cited: Not stated in the provided extract
- Judgment Length: 41 pages, 11,821 words
Summary
MAKERICKS3D LLP v Terence Lee Meng Kai ([2025] SGDC 271) arose from a failed influencer-product review arrangement that escalated into public online statements. The claimant, a bicycle parts business operating through Shopee, sued the defendant influencer in the torts of defamation and malicious falsehood after the defendant posted content on Facebook and Instagram (and also shared related material on TikTok) describing an incident involving damaged products and a police report. Although the posts did not explicitly name the claimant, the claimant alleged that readers would understand the posts to refer to it, and that the statements were defamatory and false.
The District Court’s analysis focused on two distinct torts with different elements. For defamation, the court examined whether the posts bore a defamatory meaning, whether they were understood to refer to the claimant, and whether the claimant established a prima facie case. For malicious falsehood, the court assessed whether the defendant published false statements, whether the defendant acted with the requisite malice (including lack of honest belief or reckless disregard), and whether the claimant proved damage to its business reputation and goodwill.
Ultimately, the case illustrates how online communications—particularly those framed as “product review” narratives—can trigger liability when they are published to a wider audience and are capable of harming commercial reputation. It also demonstrates the evidential importance of proving reference, defamatory meaning, falsity, and malice in the context of social media posts.
What Were the Facts of This Case?
The claimant, MAKERICKS3D LLP, is a limited liability partnership engaged in inventing, designing, and selling bicycle parts. Its products are sold on the Shopee online shopping platform. While the action was brought in the claimant’s name, the relevant events centred on one of its partners, Ms Tan Ying Hui, who is also known as “Alice”. The defendant, Terence Lee Meng Kai, is an influencer within the cycling enthusiast community. He runs a website and maintains social media accounts on platforms including Facebook, Instagram, YouTube, and TikTok under the handle “Bikeguru.sg”. By May 2024, he had over 11,000 followers on Facebook and over 1,600 followers on Instagram, giving his posts a potentially meaningful reach.
In September 2022, Alice was introduced to the defendant. Over the following month, Alice passed two bicycle accessories—an “M Snap” and an “M Spring”—to the defendant with the intention that he would review them. The claimant described the M Snap as a space-making accessory that allows users to mount items such as mobile phones and lights, and the M Spring as a pair of accessories that prevents hinge plate misalignment and facilitates tightening of hinges. The claimant also asserted that these accessories are well-known within the Brompton bicycle community in Singapore.
However, the defendant decided not to proceed with the review. On 24 December 2022, he informed Alice that she could collect the accessories from his condominium. Alice requested that the defendant return the items by post, and the defendant agreed. On 23 January 2023, the defendant informed Alice that the M Snap had a crack and that the M Spring had torn when he was removing it from his bicycle. He attributed the damage to a difficult ride he had done while reviewing the accessories in December 2022. Alice collected the accessories from the defendant on the same day.
The parties’ accounts diverged on what happened during the handover and the defendant’s response to accusations. The claimant’s position was that Alice met the defendant at the condominium entrance and asked for an honest explanation of how the accessories had been damaged. The defendant claimed he had crashed his bicycle in Malaysia and only discovered the damage when unscrewing the accessories. Alice responded that the damage looked like it had been deliberately caused by tools. The defendant, according to the claimant, chose not to respond and left. The defendant’s version did not contradict the general narrative of damage, but added that Alice was accompanied by two other representatives (including Mr Jeffrey Kang and another unidentified man). The defendant said he did not respond because the accusations were baseless and untrue and because he feared for his safety. He also said the representatives were hostile and confrontational, prompting him to make a police report.
What Were the Key Legal Issues?
The court had to decide whether the defendant’s Facebook and Instagram posts were actionable in defamation. This required consideration of multiple elements: whether the posts were capable of bearing a defamatory meaning; whether the posts referred to the claimant (or were understood by readers as referring to it); and whether the claimant could establish a prima facie case that the publication was to third parties. Because the posts did not name the claimant, the “reference” issue was particularly important. The claimant pleaded that readers would understand the posts, with the benefit of hindsight, to refer to it and to the events leading to the breakdown of the parties’ relationship.
In parallel, the court had to determine whether the claimant’s malicious falsehood claim succeeded. Malicious falsehood requires proof that the defendant published a false statement, that the statement was published maliciously (for example, without honest belief in its truth or with reckless disregard), and that the claimant suffered damage as a direct consequence of the publication. The claimant’s pleaded case was that the defendant asserted the accessories were damaged during usage, when the claimant maintained they were deliberately damaged by tools. The claimant also pleaded that it suffered injury to its business reputation, trade reputation, and goodwill among actual and/or potential customers and business partners.
Finally, the court had to consider remedies. Even where liability is established, the appropriate relief in defamation and malicious falsehood may differ, and the claimant’s ability to prove the extent of harm can affect the scope of damages and other orders.
How Did the Court Analyse the Issues?
The District Court approached the matter by separating the defamation and malicious falsehood analyses. For defamation, the court first considered whether the posts were capable of being understood in a defamatory sense. The posts were framed as a personal narrative about the defendant’s life journey as a cycling influencer, but they included a detailed account of an incident: an agreement to review products “after a period of usage FOC”, an argument between the product owner and her boyfriend against the defendant and a fellow follower, the defendant’s decision not to review, the return of the products, and the defendant’s discovery that the products were damaged. The posts also described the defendant being questioned by the owner and two men, and the defendant’s decision to leave for safety reasons. The posts concluded with advice to bicycle shop owners/companies about how the defendant would review products and how ownership works during review arrangements.
Although the posts did not explicitly refer to the claimant by name, the court examined whether the natural and ordinary meaning, implied meaning, inferred meaning, or innuendo could convey defamatory imputations. In defamation law, the court’s focus is on what the words would convey to reasonable readers. Here, the narrative suggested that the claimant’s partner and her associates had accused the defendant of deliberately damaging the products, and that the defendant had lodged a police report. The claimant’s case was that the posts, read in context and with hindsight, would be understood to refer to the claimant and to imply wrongdoing or misconduct connected to the damaged accessories and the breakdown of the relationship.
Reference was a central battleground. The court had to determine whether the posts were “about” the claimant in the sense required for defamation. Where a claimant is not named, reference can still be established if readers would identify the claimant from contextual clues. The court’s analysis therefore considered the content of the posts, the relationship between the parties, and the likelihood that the defendant’s audience—particularly those familiar with the cycling community and the influencer’s interactions—would understand the posts to refer to the claimant. The claimant pleaded that the posts were obviously about, among other things, the events that led to the breakdown of the parties’ relationship, and that readers could identify the claimant with the benefit of hindsight.
On publication, the court accepted that the posts were published because they were posted on Facebook and Instagram and were accessed, downloaded, and/or read by third parties. Once publication and reference were established, the court assessed whether the claimant had made out a prima facie case of defamation. The court then turned to defences and remedies, though the provided extract does not include the specific defences raised or the court’s final findings on them. In defamation cases involving social media, common defences include truth, honest opinion, privilege, and publication-related defences; however, the extract does not specify which were argued in this case.
For malicious falsehood, the court analysed the elements in a structured way: (i) whether there was a false statement; (ii) whether the defendant acted with malice; and (iii) whether damage was proved. The claimant’s pleaded falsehood was that the defendant asserted the accessories were damaged in the course of usage, when they were allegedly deliberately damaged by tools. The defendant’s narrative, by contrast, was that he discovered the damage after uninstalling the products from his bicycle and that the damage may have been caused by impact during overseas cycling training. The court also considered that the defendant posted photographs of the police report, and that a TikTok post contained the same photographs. The police report photographs included a statement that the defendant decided to uninstall the products and realised all three products were damaged, and that he informed the claimant that it might have been damaged during his overseas trip.
Malice in malicious falsehood is not identical to malice in defamation. It generally requires proof that the defendant lacked honest belief in the truth of the statement or acted with reckless disregard for whether it was true. The court therefore examined the defendant’s state of mind and the basis for his assertions. The defendant’s account included that he believed the accusations were baseless and untrue and that he feared for his safety, which he said explained why he made a police report. The court’s reasoning would have had to reconcile these claims with the claimant’s evidence that the accessories were deliberately damaged and that the defendant’s public statements were therefore false.
Finally, the court addressed damage. In malicious falsehood, damage to business reputation and goodwill is a key requirement. The claimant pleaded injury to its business reputation, trade reputation, and goodwill among actual and/or potential customers and business partners, and also pleaded special damage as a direct, natural, and/or ordinary consequence of the publication. The court’s findings on damage would have depended on the evidence adduced—such as proof of lost sales, reputational harm, or other commercially measurable consequences—though the extract does not include those evidential details.
What Was the Outcome?
The provided extract truncates the judgment before the court’s final conclusions on liability and remedies. Accordingly, the specific orders—whether the defamation claim, malicious falsehood claim, or both were allowed or dismissed; whether damages were awarded; and whether injunctive or declaratory relief was granted—cannot be stated with confidence from the text supplied.
Nevertheless, the judgment’s structure indicates that the court made findings on “Issue 1: The Defamation Claim” (including whether a prima facie case was made out and what defences applied) and “Issue 2: The Malicious Falsehood Claim” (including false statement, malice, and damage). Practitioners should consult the full text of [2025] SGDC 271 to confirm the court’s final determinations and the precise remedies ordered.
Why Does This Case Matter?
This case matters because it addresses the legal risks of influencer communications that blend personal narrative with commercial product-related allegations. In Singapore, defamation and malicious falsehood remain potent causes of action for business entities seeking to protect reputation. The case underscores that even where a defendant does not name a claimant, liability may still arise if the publication is understood to refer to the claimant by contextual identification.
From a practical perspective, the decision is useful for lawyers advising businesses and creators on social media disputes. For claimants, it highlights the need to plead and prove reference, defamatory meaning, and publication in defamation, and to prove falsity, malice, and damage in malicious falsehood. For defendants, it illustrates that posting screenshots or excerpts of third-party documents (such as police report photographs) does not automatically immunise a publisher if the underlying assertions are contested and the publication is made without honest belief or with reckless disregard.
For law students and practitioners, the case also demonstrates how courts compartmentalise tort elements rather than treating defamation and malicious falsehood as interchangeable. Even where the same publication underlies both claims, the evidential burdens and legal tests differ. This can affect litigation strategy, including how parties frame their evidence, how they address the defendant’s state of mind, and how they quantify reputational and commercial harm.
Legislation Referenced
- Not stated in the provided extract.
Cases Cited
- Not stated in the provided extract.
Source Documents
This article analyses [2025] SGDC 271 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the full judgment for the Court's complete reasoning.