POFMA in Singapore – Balancing Free Speech and Truth in the Digital Age

INTRODUCTION

In an era where information travels at breakneck speed, stemming the flow of falsehoods is a critical challenge for governments worldwide. The introduction of the Protection from Online Falsehoods and Manipulation Act (POFMA) in Singapore is a strategic and necessary response to tackle this challenge.

While some critics have argued that POFMA curtails freedom of speech, has the tendency to lead to self-censorship, and even undermines democratic values, a closer examination reveals that it is a necessary tool to safeguard public interest and maintain social harmony in a rapidly changing information dissemination landscape.

This article examines whether POFMA strikes the appropriate balance between the competing needs of our society while adequately protecting the right to free speech in Singapore.

HISTORICAL CONTEXT OF FREEDOM OF SPEECH

Freedom of speech has long been recognised as a fundamental human right and a cornerstone of democratic societies. Historically, the ability to speak freely had proved pivotal in shaping societies, challenging injustices and authoritarian regimes, and enabling societal progress.

The Enlightenment era in Europe in the 17th and 18th century, for instance, saw the rise of free speech to combat authoritarianism and promote intellectual and cultural development. The American Revolution and the French Revolution also fuelled the dissemination of ideas and promoted cherished ideals of freedom and equality.

The right to free speech belongs not only to liberal western societies. Free speech has been warmly embraced and championed as a universal human right in the Universal Declaration of Human Rights (UDHR), which was adopted by the United Nations General Assembly on 10 December 1948. Article 19 of the UDHR proclaims that:

“Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers.”

Locally, the right for every citizen in Singapore to freedom of speech and expression is also enshrined in Article 14 of the Singapore Constitution.

FREEDOM OF SPEECH AS A TOOL TO AVOID ANARCHY

While this may seem counter-intuitive to those in power, freedom of speech in fact serves as an important tool to avoid anarchy by allowing for a peaceful outlet for grievances to be aired and by enabling constructive public discourse to flourish. When individuals and groups are allowed to express their views openly, it reduces the tendency to resort to violence as a means of being heard. This principle underpins democratic societies, where open dialogue and debates are essential for addressing social issues, seeking consensus, and driving progress.

FREEDOM OF SPEECH NOT AN ABSOLUTE RIGHT

However, freedom of speech is not an absolute right to be protected at all costs. Freedom of speech needs to be exercised responsibly.

There is no society today which protects free speech absolutely. The challenge for any society is to create a legal framework that protects free speech while mitigating its potential to incite violence, spread falsehoods, and fracture social cohesion.

In Singapore, the fact that broader societal concerns such as public peace and order must be engaged in a balancing exercise with the enjoyment of the personal liberty of freedom of speech is expressly recognized in Article 14(2)(a) of the Singapore Constitution which sets out that:

“…14(2) Parliament may be law impose –

(a)On the rights conferred by clause (1)(a), such restrictions as it considersnecessary or expedient in the interest ofthe security in Singapore of any partthereof, friendly relations with othercountries, public order or morality and restrictions designed to protect the privileges of Parliament or to provide against contempt of court, defamation or incitement to any offence …”

THE LIMITS OF UNBRIDLED FREEDOM OF SPEECH

Not all types of speech are equal. Some forms of expression, such as defamation, hate speech, and incitement to violence, and defamation, can cause severe adverse consequences and restrictions to these types of speech are universally accepted to be legitimate and warranted.

It is apposite to quote the Singapore High Court’s decision in The Online Citizen Pte Ltd v AG [2020] SGHC 36 at [35] which pertinently highlights that the right to free speech does not include the right to spread falsehoods:

“…Place, time and circumstance govern the Constitutional freedom of expression, and it is clear that Art 14 does not immunise every use of speech. In particular, “a wholly unrestricted right to free speech (assuming for the moment this exists at all) does not extend to a wholly unrestricted right to deceive or to maintain a deception by not drawing attention to the falsehood”: see Attorney- General v Ting Choon Meng and another appeal [2017] 1 SLR 373 (“Ting Choon Meng”) at [112]. Put differently, the right to free speech pertains to the communication of “information not misinformation”: see Reynolds v Times Newspapers Ltd and others [2001] 2 AC 127 at 238 (“Reynolds”). It is observed that while the law must be vigilant against attempts to check the expressions of tastes and opinions contrary to our own, there is no public interest in preserving a right to disseminate falsehoods. To the contrary, “purveying as facts statements which are not true is destructive of the democratic society”: Reynolds at 238.”

Different societies have different thresholds for what constitutes acceptable speech. This is understandably shaped by their cultural, historical, and social contexts. For example, Holocaust denial is illegal in several European countries due to its historical impact in recognition of the evils of anti-Semitism in modern history. Similarly, many countries have laws against hate speech to protect vulnerable minority communities and to maintain social harmony and public safety.

In Japan, the Act on the Elimination and Control of Hate Speech was enacted in 2016 and was introduced in response to growing concerns over discriminatory speech and actions targeting ethnic minorities, particularly Korean residents in Japan. This discrimination against Korean residents in Japan has a historical dimension, dating back to the colonial era and exacerbated by national sentiments during and post-World War 2.

In India, the Indian Penal Code contains provisions prohibiting enmity between different groups on grounds of religion, race, place of birth, residence, language, etc.

THE EVOLUTION OF INFORMATION DISSEMINATION

The way information is disseminated has evolved dramatically over the centuries. From oral traditions and handwritten manuscripts to the invention of the printing press and the rise of social media, each technological advancement has transformed how information spreads and is consumed.

In this digital age, social media platforms have become the primary means of communication for millions of people across the world, including here in Singapore.

In a recent Statista survey, Singapore was amongst the countries with the highest internet penetration rate as of April 2024 at 96%. Further, even back during the POFMA parliamentary debates back in 2019, a Business Times report had stated that 70% of Singaporeans are active social media users on mobile devices, double the global average of 34%. The same report found that over three- quarters of Singaporeans used social media. This percentage would likely have increased since then.

Anecdotally speaking, Singaporeans no longer only consume news from the traditional mainstream media but often through alternative independent media and even through social media. This rapid and often unregulated flow of information presents new challenges, including the spread of misinformation and disinformation. The anonymity afforded by the internet presents a further challenge in identifying wrongdoers while the viral nature of social media also means that falsehoods can reach vast audiences in an instant, making it extremely difficult to contain their impact.

In this environment, distinguishing between gossip, news, and deliberate falsehoods becomes crucial. Effective regulation must be introduced to prevent the harmful effects of misinformation and must be nimble enough to address the new challenges presented by this digital age.

FALSEHOODS TRAVEL FASTER THAN TRUTH

An interesting observation pointed out during the POFMA parliamentary debates is that falsehood often travels faster than truth.

This is said to be due to several factors inherent in human psychology and the dynamics of information dissemination. One key factor is the novelty and sensationalism associated with false information, which can capture people’s attention and elicit strong emotional responses. Falsehoods often align with preconceived beliefs or biases, making them more likely to be shared within social circles and online communities. In contrast, truth may be perceived as mundane or less attention-grabbing, reducing its virality.

The rise of social media and digital communication has also accelerated the spread of falsehoods by providing platforms for rapid sharing and amplification. It is not uncommon for messages on WhatsApp, for example, to be quickly forwarded to one’s contacts or group of contacts. Algorithms that prioritize engagement and clickbait further contribute to the viral spread of sensationalistic content, regardless of its veracity.

Moreover, the financial reward model of social media also encourages the hosting and spread of falsehoods to attract views and “likes” since falsehoods are more salacious than truths.

THE ROLE OF SOCIAL MEDIA ALGORITHMS AND BOTS IN MANIPULATING OPINION

What further exacerbates the challenges to tackling the spread of online falsehoods is the role of social media algorithms and bots.

Social media platforms utilize complex algorithms to determine what content users see. These algorithms often prioritize content that generates strong emotional responses, such as outrage or fear, which can amplify the spread of falsehoods. Social media algorithms are also designed to maximize user engagement by showing content that aligns with users’ preferences and behaviour. This can create echo chambers, where users are exposed primarily to information that reinforces their existing beliefs, making them more susceptible to misinformation.

Automated accounts, or bots, on the other hand, can be used to spread false information quickly and efficiently. Bots can amplify certain messages, create the illusion of consensus, and manipulate public opinion and influence public discourse.

Individuals and groups can thus leverage on the biases of the social media platform algorithms and, coupled with the use of bots (in the hundreds, thousands, or more), be deployed to conduct misinformation campaigns which can be tailored to target specific user-profiles.

THE ROLE OF SOCIAL MEDIA COMPANIES AND THE INADEQUACY OF SELF-REGULATION BY SOCIAL MEDIA COMPANIES

As can be seen from the above, the challenges posed by the spread of deliberate online falsehoods are numerous and significant.

Social media companies have an important role to play to help curb the spread of online falsehoods on their own platforms. Social media companies could self-regulate the content that is posted on their platforms. There are various tools that social media companies could deploy such as automated systems (based on algorithms and AI) and human moderation systems to detect and flag out deliberate online falsehoods. They could also set out user reporting mechanisms to provide users with tools to report false information.

In terms of limiting the virality of the false content posted on their platforms, social media companies can also do their part. For one, in response to the 2018 “WhatsApp Lynching” Incidents in India mentioned earlier, WhatsApp introduced messaging forwarding restrictions to curb the spread of misinformation and viral falsehoods. WhatsApp also started labelling how many times a message has been forwarded, thus allowing users to judge the credibility of the message. While this certainly helps to slow down the spread of misinformation by limiting the ability of such messages to go viral, they are by themselves inadequate to tackle the problem.

It would also be foolish to expect that self- regulation by social media companies alone would be adequate to curb the spread of misinformation. The difficulties stem from, amongst others, the following:

• Divergent Interests / Primarily Profit Motivated: Social media companies are profit-driven and would therefore be incentivised to prioritise sensational or misleading content which can drive higher user-engagement and thus more ad revenue. This conflicts directly with the interest of preventing the spread of falsehood. These companies may also be reluctant to take any strong and decisive actions against popular accounts or content which drive online traffic, even if they spread false information, as to do so would be counter to their commercial self- interest.
• Lack of Accountability: The content moderation is often opaque and without external regulation, the social media companies are not incentivised to be accountable for their actions or lack thereof. This makes it difficult to assess whether the self-regulation efforts are effective. The social media companies are also beholden ultimately only to their shareholders and not to the citizens of the countries they operate in.
• Inconsistent Enforcement: The social media companies’ policies and enforcement practices may differ from one platform to another. This leads to potentially unequal treatment of false information. Global social media platforms may also not appreciate the particular cultural sensitivities of local communities.

PURPOSE OF POFMA

In the opening address by the Minister for Law, Mr K Shanmugam, at the second reading of the POFMA Bill, he outlined the “fundamental problem in many countries…[being] a serious loss of trust in governments, in institutions both public and private, including the political system, the media, professionals, businesses, financial institutions and so on” and a “weakening of the infrastructure of fact” caused by “falsehoods spread through new media”.

Minister Shanmugam also added that the POFMA Bill was an attempt to deal with one part of the problem i.e. “The serious problems arising from falsehoods spread through new media. And to try and help support the infrastructure of fact and promote honest speech in public discourse…”.

Section 5 of POFMA also lists the following as the purposes of POFMA:

• To prevent the communication of false statements of fact in Singapore and to enable measures to be taken to counteract the effects of such communication;
• To suppress the financing, promotion and other support of online locations that repeatedly communicate false statements of fact in Singapore;
• To enable measures to be taken to detect, control and safeguard against coordinated unauthentic behaviour and other misuses of online accounts and bots; and
• To enable measures to be taken to enhance disclosure of information concerning paid content directed towards a political end.

EXISTING LAWS PRIOR TO POFMA

Prior to the introduction of POFMA, there were two main pieces of legislation which gave the Government powers to deal with online falsehoods: the Broadcasting Act and the Telecommunications Act.

Collectively, these legislations equipped the Government with broad powers and allowed orders to be made to take down any material that is objectionable on grounds of public interest, even if the statements are true.

These statements which can be taken down also do not have to be statements of fact. They can be opinions. This is contrasted that the only statements which fall within the purview of POFMA are false statements of fact.

The purpose of the powers under those Acts were mostly used for sites and services with pornographic content, solicitation of sex, sex chats, religiously offensive content, and extremist content. Further, one thing that the Broadcasting Act lacked was that it did not apply to internet intermediaries which are outside Singapore.

POFMA focuses on tackling online falsehoods, rather than the broad areas covered under the Broadcasting Act and provides a suite of remedies which are more calibrated for dealing with false statements published on the internet. It also introduces added judicial oversight over executive action in addition to the usual judicial review mechanism available to challenge executive action.

LEGAL FRAMEWORK AND SUITE OF TOOLS AVAILABLE UNDER POFMA

POFMA provides a comprehensive legal framework specifically tailored to combat online falsehoods. The following are several key features of POFMA that enhance its effectiveness in addressing the challenges posed by misinformation:

• Tailored Suite of Tools to Combat Online Falsehoods: POFMA equips the government with a wide range of tools to combat online falsehoods. These penalties and remedies are designed to address the spread of false statements, safeguard public interest, and promote accuracy and accountability in online discourse. The available tools under POFMA include:

1. Correction Directions: Section 11 of POFMA empowers government authorities to issue correction directions requiring the correction of false statements. Individuals or organizations found to have spread false information must publish corrections alongside the original false statement to ensure that accurate information reaches the same audience.
2. Stop Communication Directions: In cases where false statements are being actively spread, authorities can issue stop communication directions to halt the further dissemination of such falsehoods. This measure aims to prevent the rapid spread of misinformation and mitigate its impact on public perception. (See Section 12 of POFMA)
3. Targeted Correction Directions: Section 21 of POFMA allows for targeted correction directions, which require corrections to be made only to specific individuals or groups who have been exposed to false statements. This enables authorities to tailor corrective measures to address the specific harm caused by misinformation.
4. Take-Down Orders: Section 22 of POFMA grants authorities the power to issue take-down orders requiring the removal of false statements from online platforms. This measure aims to prevent the continued circulation of misinformation and reduce its potential impact on public perception and discourse.
5. Bots and Fake Accounts: Under Part 6 of POFMA, a Minister may issue an Account Restriction Direction to order an internet intermediary to close any bots and fake accounts on its platform.
6. Criminal Offenses and Financial Penalties: Section 7(2), 15, and 27 of POFMA includes criminal offenses for serious violations of the law, such as maliciously spreading false information with the intent to cause public alarm or undermine public confidence. Individuals convicted of such offenses may face fines and imprisonment.

• Timely Response Mechanisms: POFMA empowers government authorities to issue correction orders and take-down directives swiftly in response to online falsehoods. This enables a quick and proactive response to combat misinformation, mitigating the potential harm caused by false narratives before they gain traction.
• Extraterritorial Reach and Enforcement: POFMA includes provisions for addressing falsehoods originating from both domestic and foreign sources, allowing authorities to take action against perpetrators regardless of their location provided that the falsehoods are communicated in Singapore. This extraterritorial reach enhances POFMA’s effectiveness in combating cross-border misinformation campaigns.
• Judicial Oversight and Safeguards: POFMA incorporates robust safeguards to prevent abuse of power and protect fundamental rights. The law includes mechanisms for judicial review and certain direct rights of appeal to the courts (see Section 17 of POFMA), ensuring that government actions are subject to independent scrutiny and accountability by the judiciary. In Singapore, the judiciary is viewed as an independent and trustworthy institution. This allows the judiciary to act as an effective check that the exercise of executive powers by the government under POFMA is in accordance with the law and the Constitution. There are also the following features, some of which are unique to POFMA.

a. The costs for filing the court papers are not unduly prohibitive.[1] There are also no hearing fees payable for the first three hearing days for the appeal (see Schedule 2 of the Supreme Court of Judicature (Protection from Online Falsehoods and Manipulation) Rules 2019)

b. Save if the appeal by the appellant was an abuse of court or the conduct of the appeal by the appellant was done “in an extravagant and unnecessary manner”, an appellant that is an individual does not have to pay any costs (see Rule 15 of the Supreme Court of Judicature (Protection from Online Falsehoods and Manipulation) Rules 2019)

c. The appeal procedure is also extremely speedy:

1. Once the court papers for the appeal has been served by the appellant, the reply affidavit has to be served within 3 working days (see Rule 7(3) of the Supreme Court of Judicature (Protection from Online Falsehoods and Manipulation) Rules 2019); and
2. Unless the appellant requests for a later working date, the hearing could be fixed by the Duty Registrar within 6 working days after the court papers have been served by the appellant (see Rule 9(3) of the Supreme Court of Judicature (Protection from Online Falsehoods and Manipulation) Rules 2019).

d.Since POFMA was introduced, 8 appeals have been made to the Courts to challenge the executive orders made. One case was partly allowed by the courts – this involved the Singapore Democratic Party that concluded in 2021.[2]

e. The constitutionality of POFMA has also been tested and affirmed by the Singapore Court of Appeal in the decision of The Online Citizen Pte Ltd v Attorney-General and another appeal and other matters [2021] SGCA 96. The Court of Appeal held that there is a nexus between the purpose of POFMA, as reflected by the public interest concerns outlined in Sections 4(d) and 4(f) of POFMA, as well as the public order exception to free speech under Article 14(2)(a) of the Singapore Constitution.

f. The same Court of Appeal also gave guidance in the form of establishing a five-step legal framework for courts to apply to analyse whether to set aside a correction direction under POFMA:

1. First, the court should start with the subject statement identified as false by the relevant minister. The court must identify the statement that the minister wishes to target by his correction direction.
2. Second, the court should determine whether the subject material being targeted makes or contains the subject statement identified by the minister, as understood according to the minister’s intended meaning. The court should consider whether the minister’s interpretation is a reasonable one. If the court finds that the subject material does not contain the subject statement identified by the minister, then the correction direction may be set aside.
3. Third, the court should determine if the identified subject statement is a “statement of fact” as defined under the POFMA.
4. Fourth, the court should determine if the identified subject statement is “false” in the sense explained in the relevant section of POFMA.
5. Fifth, the court should consider if the subject statement “has been or is being communicated in Singapore” according to POFMA.

g. The Court of Appeal also resolved two conflicting High Court decisions on which party bears the burden of proof in an appeal to set aside a correction order by holding that it was the appellant who bears the burden of proof in the appeal. The Court made this finding after considering the structure of POFMA and the wording of its provisions.

By addressing the limitations of existing laws and providing a comprehensive framework for combating misinformation, POFMA enables the Government to take the necessary action swiftly in order to curb the spread of falsehood, safeguard public trust, and to protect democratic processes in the digital age.

APPLICATION OF POFMA SINCE ITS INCEPTION

Since POFMA came into force in October 2019, it has been used in various instances to address falsehoods that have significant public impact.

According to a 17 June 2024 Straits Times article, 163 orders were issued under POFMA since the Act came into force. The majority of these orders (over a quarter of the orders) were issued related to the COVID-19 pandemic.

MAINTAINING RELIGIOUS AND RACIAL HARMONY WITH POFMA

In November 2019, when POFMA was invoked on the States Times Review Facebook page (STR). This page had alleged that the ruling People’s Action Party (PAP) would be fielding a Christian evangelist in the General Election to garner Christian votes and possibly to turn Singapore into a Christian state. Three correction directions were issued on three separate occasions, to which Mr Alex Tan, owner of STR, had ignored. As a result, Facebook was ordered to disable access for Singapore users to the page, under Section 34 of POFMA.

POTENTIAL IMPACT OF POFMA ON THE HAMAS-ISRAEL CONFLICT

The ongoing Hamas-Israel conflict is highly sensitive and complex and is an issue which is dear to certain communities in Singapore. In a situation where emotions run high and the stakes are immense, the spread of falsehoods can exacerbate tensions and may even have the potential to lead to violence.

In the context of the Hamas-Israel conflict, POFMA could serve as a valuable tool in preventing the spread of misinformation that might inflame public sentiment and disrupt social harmony. By swiftly correcting falsehoods related to the conflict, Singapore can mitigate the risk of local tensions escalating due to misinformation. For instance, if false claims about either side of the conflict were to spread in Singapore, POFMA could be used to issue corrections and provide accurate information, thus maintaining social stability and preventing any potential backlash against particular communities.

CRITICISMS OF POFMA

One common criticism of POFMA highlighted in the parliamentary debates is that the definitions of “fact” and “public interest” in POFMA are either unclear or too all- encompassing and gives far too broad a discretion to the Minister. It is consequently argued that this would cause a “chilling- effect” on free speech in Singapore.

These two definitions are important as under Section 10 of POFMA, a Minister may instruct a Competent Authority to issue a Correction Direction if the following conditions are satisfied:

(a) A false statement of fact has been or is being communicated in Singapore; and

(b) The Minister is of the opinion that it is in the public interest to issue the Direction.

A “statement of fact” is defined under Section 2(2)(a) of POFMA as “a statement which a reasonable person seeing, hearing or otherwise perceiving it would consider to be a representation of fact”.

Further, under Section 2(2)(b) of POFMA, a statement is “false” if it is “false or misleading, whether wholly or in part, and whether on its own or in the context in which it appears”.

For the purposes of POFMA, Section 4 also sets out that it is “in the public interest” to do anything if the doing of that thing is necessary or expedient –

(a) in the interest of the security of Singapore or any part of Singapore;

(b) to protect public health or public finances, or to secure public safety or public tranquility;

(c) in the interest of friendly relations of Singapore with other countries;

(d) to prevent any influence of the outcome of an election to the office of President, a general election of Members of Parliament, a by-election of a Member of Parliament, or a referendum;

(e) to prevent incitement of feelings of enmity, hatred or ill-will between different groups of persons; or

(f) to prevent a diminution of public confidence in the performance of any duty or function of, or in the exercise of any power by, the Government, an Organ of State, a statutory board, or a part of the Government, an Organ of State or a statutory board.

Under Section 17(5) of POFMA, the Courts may only set aside a Correction Direction on the following grounds on an appeal:

(a) the person did not communicate in Singapore the subject statement;

(b) the subject statement is not a statement of fact, or is a true statement of fact;

(c) it is not technically possible to comply with the Direction.

It has therefore been pointed out that the wide definition of “public interest” is particularly concerning because it does not fall within the 3 limited grounds in Section 17(5) of POFMA, such that the issue of whether the Minister was correct or not in arriving in his opinion that it is in the public interest to issue the Correction Direction cannot be decided by the Court on appeal. Any such challenge would thus only be by way of a judicial review.

Further, and even though it has been explained by the Government that POFMA does not apply to statements of opinion, many commentators have said that the distinction between a statement of fact and opinion may not always be easy to draw.

In a letter dated 24 April 2019 to then Minister of Communications and Information, Minister S Iswaran, a group of 27 journalist have highlighted that “[o]pinion writers regularly cite facts to back up their positions, and a journalist’s interpretation and presentation of a set of facts might contradict a minister’s own understanding of what took place”.

In response to concerns about the wide definitions of “public interest” and “facts”, the response from Minister Shanmugam in his 3 May 2019 article in the Straits Times is that these definitions are “based on existing jurisprudence”.

In respect of the criticisms of what constitutes “public interest” and the limited judicial scrutiny over it, this may be justified on the basis that it is the executive who is best placed to determine what exactly are issues of public interest. The executive has access to comprehensive information (including classified information / documents) and they also have their fingers on the pulse as to what actions are required to safeguard the public interest. The issue of what constitutes the public interest and what is required to safeguard the “public interest”. There is, of course, always the concern that a self-serving and corrupt executive could take a wholly unreasonable interpretation of “public interest”. However, in such cases, judicial review is still available. In any event, such matters cannot be kept secret for long and once uncovered will likely lead to condemnation in the court of public opinion and a loss of democratic mandate.

In respect of the distinction between “facts” and “opinion”, this remains a difficult distinction although based on Section 17(5) of POFMA, the Courts would be able to play a role to help clarify this distinction to ensure that the full protection intended by POFMA is afforded with as little impact as possible on the right to free speech.

Anecdotally and based on the available statistics, it also does not appear that the “chilling effect” to free speech predicted by critics has materialised.

Nevertheless, one possible improvement to help achieve an appropriate balance is for the relevant Ministry to increase its reliance on first issuing letters to invite a removal or correction of the false online publication. Only if there is a failure to response should a Correction Direction or order directions/orders then be issued. It is hoped that the MHA and other ministries will consider, where appropriate, relying on such letters as a first port of call before resorting to any tools under POFMA.

CONCLUSION

While critics may still not be convinced, POFMA is a critical tool in balancing the protection of free speech with the need to safeguard public interest and social harmony.

This client update was authored by our Managing Partner, Bazul Ashhab

You can download a PDF copy of this article here

[1] S$200 for the filing of the Originating Application and S$1 per page for the affidavit filed

[2] See Straits Times Article titled “Govt to continue studying if levers beyond Pofma are needed to tackle deepfakes, online fake news” dated 17 June 2024, by Goh Yan Han