but would undoubtedly cause feelings of ill-will or hostility within the Malay community as well. Also, the seditious publications distributed by the accused persons which disparaged the Roman Catholic Church and other faiths were held to have affected followers comprising "different races and classes of the population in Singapore". Academic criticism Several academics have pointed out the weaknesses of section 3(1)(e) as a benchmark for what constitutes a seditious tendency. Emphasis on potential harm A literal reading of section 3(1)(e) indicates that the provision does not require proof that an act has the propensity to cause violence. In contrast, Article 149(1)(c) of the Constitution of the Republic of Singapore, which authorizes anti-subversion legislation, contains the additional words "likely to cause violence", which implies that section 3(1)(e) sets a lower threshold than Article 149. This is consistent with how the courts have interpreted section 3(1)(e), as the cases do not address the likelihood of the seditious acts to cause harm. In other words, freedom of speech and expression is limited solely because of its potential consequences, the magnitude of which is categorically assumed. However, it is arguable whether acts promoting class hatred which do not incite violence should in themselves be termed "seditious". Feelings as unreliable indicator It is difficult to apply "feelings" as a basis for constraining speech as they are inherently subjective and difficult to measure. Furthermore, section 3(1)(e) is silent as to which audience a tendency should be evaluated by – the actual audience or an audience of "reasonable persons". The same deed may produce different "feelings" depending on the temperament of the audience, as "language which would be innocuous, practically speaking if used to an assembly of professors or divines, might produce a different result if used before an excited audience of young and uneducated men". Due to such ambiguity, people are left without clear guidelines as to what constitutes a seditious tendency, which may result in the chilling of free speech. Another criticism is the risk that courts may place too much emphasis on subjective feelings, which may not be a reliable basis for restricting free speech. If a subjective test is adopted, people who wish to express views on racial and religious issues may find themselves held hostage to segments of the population who may be oversensitive and more prone to finding offence than others. Hence, District Judge Neighbour's reliance in Ong Kian Cheong on