In "Ong Kian Cheong", the accused persons argued that in order for section 3(1)(e) of the Act to be consistent with the right to freedom of speech and expression guaranteed to Singapore citizens by Article 14(1)(a) of the , it had to be limited to actions expressly or impliedly inciting public disorder. The District Court disagreed, stating that if Parliament had intended to include this additional requirement, it would have expressly legislated to that effect in the Act. The High Court and Court of Appeal have yet to render any judgment on the issue. According to one legal scholar, "Koh Song Huat Benjamin" and "Ong Kian Cheong" indicate that in Singapore freedom of speech is not a primary right, but is qualified by public order considerations couched in terms of racial and religious harmony. It has also been posited that if Article 14 is properly interpreted, section 3(1)(e) of the Sedition Act is not in line with it.