maintenance of government. A District Court held in Public Prosecutor v. Ong Kian Cheong (2009) that on a plain and literal reading, there is no suggestion that Parliament intended to embody the common law of seditious libel into section 3(1)(e). Since prosecutions under the Sedition Act since 1966 have been based on section 3(1)(e), a distinctive feature of the use of the Act in the 21st century is that it has primarily been employed to deal with disruptions to racial and religious harmony. Interpretation of section 3(1)(e) Feelings of ill-will and hostility In Public Prosecutor v. Koh Song Huat Benjamin (2005), the accused persons pleaded guilty to doing seditious acts tending to promote feelings of ill-will and hostility. The acts in question were the posting of invective and pejorative anti-Malay and anti-Muslim remarks on the Internet. Given that "[r]acial and religious hostility feeds on itself", such "feelings" may spread and multiply, and they need not be confined to the direct impact of the seditious act itself. In Ong Kian Cheong, the accused persons were convicted of distributing seditious publications tending to promote feelings of ill-will and hostility, namely, evangelical tracts that promoted Protestant Christianity and denigrated Islam, and which were described as a "pointed attack by one religion on another". Not only would such seditious tendencies be obvious to any reasonable man, the recipients of the tracts testified that they felt angry after reading the publications. District Judge Roy Grenville Neighbour found that the recipients' testimony "clearly proves that the publications have a seditious tendency". Between different races or classes Section 3(1)(e) of the Sedition Act refers to promoting "feelings of ill-will and hostility between different races or classes of the population of Singapore". In contrast to the other limbs of section 3(1), which mainly aim to capture acts of subversion directed at the established government, section 3(1)(e) relates to the inflaming of ethno-religious sensitivities. However, the words races and classes have been interpreted rather loosely when applying the Sedition Act. It appears that the two words are sufficiently malleable to include religious groups and cater to other types of inter-group hostility. For instance, in Ong Kian Cheong there was a tendency to conflate ethnicity with religious affiliation. This inclination to associate race with religion may stem from the fact that in Singapore, most Malays are Muslims and vice versa. Therefore, religious publications denigrating Islam would not only affect Muslims,