violence against government institutions, and horizontal effect because it criminalizes statements which harm the relationships between sectors of the community. Professor Thio has argued that the Sedition Act should be reserved for politically motivated incitements of violence which threaten the life of the state and its institutions, and that public order problems of feelings of ill-will and hostility between different races or classes should not be prosecuted under the umbrella of sedition. In other words, the vertical aspect of sedition should be retained, but there should be separate legislation for the horizontal aspect. Such a separate statutory provision could set out precise norms to regulate harmful non-political forms of speech with the goal of managing ethnic relations and promoting national identity. This would bring clarity to the underlying free speech theories involved. The proposal is supported by the view of Professor Tan Yock Lin that when construing section 3(1)(e) in the light of the preceding four limbs, it could only have been intended to embody one of the many forms of seditious libel and must be construed so as to require proof of defiance of constituted authority. Notable uses of sedition laws On or about 10 May 1954, the University Socialist Club of the University of Malaya in Singapore published issue 7 of the Club's newsletter Fajar ("Dawn" in Malay). Eight students involved in the publication were charged under the Sedition Ordinance 1938 (S.S.) with possessing and distributing the newsletter, which was claimed to contain seditious articles that criticized the British colonial government. The students included Poh Soo Kai, James Puthucheary and Edwin Thumboo. They were represented by Lee Kuan Yew and Denis Nowell Pritt, Q.C. On 25 August, following a two-and-a-half-day trial, the First Criminal District Court accepted Pritt's submission of no case to answer. The judge, Frederick Arthur Chua, ruled that the newsletter was not seditious and acquitted the students. Two Barisan Sosialis Members of Parliament, Chia Thye Poh and Koo Young, were charged with sedition after publishing the 11 December 1965 issue of the Chern Sien Pau, the Chinese edition of the party organ The Barisan, which claimed that the People's Action Party government was "plotting to murder" Lim Chin Siong, a left-wing politician who had founded the Barisan Sosialis. On 26 July 1966, the defendants were found guilty and sentenced to a fine of $2,000 each. They appealed against their convictions but subsequently withdrew the appeals.