Secondly, section 3(1)(e) differs from the classic common law idea of sedition because there is no requirement that the seditious tendency has to be directed against the 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.