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".