Twenty-seven years ago, Peter English rightfully lamented that the scope of the defence of duress in criminal law in Singapore was far too limited, and this was especially worrying in view of the availability of capital and mandatory sentences in this jurisdiction.3 Criticisms of the defence being too restrictive and proposals for reform have also been made by other writers4 and the Law Commission of India.

Constitutional law scholars in Singapore often wait for years in eager anticipation of a landmark decision from the Court of Appeal concerning the ambit of fundamental rights guaranteed in the Singapore Constitution. Unlike other areas of law, for instance tort law, there have been few such iconic decisions over the last couple of decades. On 8 October 2021, in The Online Citizen v The Attorney-General, a five-member full bench of the Singapore Court of Appeal, handed down a joint unanimous decision on whether the correction directions issued by the Minister of Home Affairs against allegedly false statements of fact under the Protection from Online Falsehoods and Manipulation Act 2019 impermissibly restricted freedom of speech under Article 14 of the Singapore Constitution and were unconstitutional.