M Badiuzzaman v Salma Islam: Defamation Claim by Singaporean Family Against Bangladeshi Media

In M Badiuzzaman v Salma Islam, the General Division of the High Court of Singapore ruled in favor of the claimants, a Singaporean family, in a defamation suit against the defendants, who published defamatory remarks in media owned by Jugantor, a Bengali daily newspaper in Bangladesh. The court found that the publications accused the claimants of criminal activities, including illegal asset accumulation and money laundering. The court awarded general damages to the claimants but denied aggravated and special damages. The court will hear counsel on costs at a later date.

1. Case Overview

1.1 Court

General Division of the High Court of the Republic of Singapore

1.2 Outcome

Judgment for Claimants

1.3 Case Type

Civil

1.4 Judgment Type

Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Singaporean family sues Bangladeshi media for defamation over articles alleging illegal asset accumulation and money laundering. Court finds in favor of the claimants.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
M BadiuzzamanClaimantIndividualGeneral Damages AwardedPartial
Nasreen ZamanClaimantIndividualGeneral Damages AwardedPartial
Ehsanuzzaman RajibClaimantIndividualGeneral Damages AwardedPartial
Najib ZamanClaimantIndividualGeneral Damages AwardedPartial
Tania ZamanClaimantIndividualGeneral Damages AwardedPartial
Salma IslamDefendantIndividualLostLost
Saiful AlamDefendantIndividualLostLost
Fahim AhmedDefendantIndividualLostLost
Shahim IslamDefendantIndividualLostLost

3. Judges

Judge NameTitleDelivered Judgment
Choo Han TeckJudge of the High CourtYes

4. Counsels

Counsel NameOrganization
Chong Yee LeongAllen & Gledhill LLP
Liew Pei Jun AnnetteAllen & Gledhill LLP
Justin William JeremiahAllen & Gledhill LLP
Elias Benyamin ArunAllen & Gledhill LLP

4. Facts

  1. The claimants are a Singaporean family originally from Bangladesh.
  2. The claimants have a family business, Tania International Pte Ltd, part of the Tania Group.
  3. The defendants published alleged defamatory remarks in media owned by Jugantor.
  4. The Sep 2020 Defamatory Statements concerned Mr Badiuzzaman and Mrs Zaman.
  5. The YouTube Defamatory Statements concerned Mr Badiuzzaman.
  6. The Jan 2021 Defamatory Statements concerned all the claimants.
  7. The claimants sought general, aggravated, and special damages, as well as a permanent injunction.

5. Formal Citations

  1. M Badiuzzaman and others v Salma Islam and others, Originating Claim No 332 of 2022, [2023] SGHC 311

6. Timeline

DateEvent
Sep 2020 Defamatory Statements published on Jugantor’s website
YouTube Defamatory Statements published on YouTube Channel
Jan 2021 Defamatory Statements published on Jugantor’s website
Anti-Corruption Commission of Bangladesh commenced investigation against Mr. Badiuzzaman and Mrs. Zaman
Bank of Singapore cancelled mortgage facility of MBZ Global Holdings Limited
Mr Badiuzzaman borrowed money from VM Credit Pte Ltd
Claimants’ lawyers sent letters of demand to the 1st and 2nd defendants
Claimants’ lawyers sent letters of demand to the 3rd and 4th defendants
Judgment reserved
Judgment

7. Legal Issues

  1. Defamation
    • Outcome: The court found that the defendants had defamed the claimants through publications accusing them of criminal activities.
    • Category: Substantive
  2. Aggravated Damages
    • Outcome: The court held that aggravated damages were not warranted in this case.
    • Category: Remedial
    • Related Cases:
      • [2013] 4 SLR 629
      • [2001] 1 SLR(R) 86
  3. Special Damages
    • Outcome: The court held that special damages should not be awarded as there was insufficient evidence to link the cancellation of the loan facility to the damage to Mr Badiuzzaman’s reputation.
    • Category: Remedial
    • Related Cases:
      • [2014] 1 SLR 639
      • [2022] SGHC 292

8. Remedies Sought

  1. General Damages
  2. Aggravated Damages
  3. Special Damages
  4. Permanent Injunction

9. Cause of Actions

  • Defamation

10. Practice Areas

  • Defamation Law
  • Civil Litigation

11. Industries

  • Media
  • Banking

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Koh Sin Chong Freddie v Chan Cheng Wah Bernad and others and another appealCourt of AppealYes[2013] 4 SLR 629SingaporeCited for the circumstances warranting aggravated damages in defamation cases.
Arul Chandran v Chew Chin Aik VictorHigh CourtYes[2001] 1 SLR(R) 86SingaporeCited for the circumstances warranting aggravated damages in defamation cases.
Low Tuck Kwong v Sukamto SiaHigh CourtYes[2014] 1 SLR 639SingaporeCited for the principle that special damages in defamation must flow from losses referable to the damage to reputation.
Continental Steel Pte Ltd v Nippon Steel & Sumitomo Metal Southeast Asia Pte Ltd and anotherHigh CourtYes[2022] SGHC 292SingaporeCited for the principle that special damages in defamation must flow from losses referable to the damage to reputation.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
No applicable statutes

15. Key Terms and Keywords

15.1 Key Terms

  • Defamation
  • Jugantor
  • Tania International Pte Ltd
  • MBZ Global Holdings Limited
  • General Damages
  • Aggravated Damages
  • Special Damages

15.2 Keywords

  • defamation
  • Singapore
  • Bangladesh
  • media
  • family business
  • general damages

17. Areas of Law

Area NameRelevance Score
Defamation95
Civil Litigation60
Civil Practice50
Evidence Law40
Evidence40
Costs20
Injunctions15

16. Subjects

  • Defamation
  • Tort Law
  • Media Law