Anonymous online? How the courts identified the blogger behind Papagomo

On 17 September 2026, Malay Mail reported that the blogger known as Papagomo had failed to obtain a stay of a May 2026 High Court defamation judgment in favour of Lim Guan Eng and his son. An appeal in that suit is pending. The report is a reminder of an earlier case involving the same blogger, Datuk Seri Anwar bin Ibrahim v Wan Muhammad Azri bin Wan Deris, which shows how a Malaysian court deals with a defendant who says that the pseudonym on the blog is not theirs.

A pseudonymous blog and a RM100 million claim

In March 2013, shortly before the 13th General Election, a blog called Papagomo published posts and images making allegations of a sexual nature about Datuk Seri Anwar Ibrahim, who was then the Opposition Leader. We do not repeat them. Anwar sued in the High Court in Kuala Lumpur, claiming RM100 million.

The defendant denied that he was Papagomo and denied owning the blog. At the same time he pleaded justification (that the allegations were true) and fair comment, defences found in sections 8 and 9 of the Defamation Act 1957, as well as qualified privilege. Before any of those defences could matter, the court had to answer a question of fact: who was behind the blog?

Proving who is behind the keyboard

According to reports of the judgment, the High Court did not rest its finding on the statutory presumptions in section 114A of the Evidence Act 1950. It relied on ordinary evidence. A fellow blogger testified that the defendant had introduced himself as Papagomo at a bloggers’ gathering, and a photograph supported that account. The judge, Rosilah Yop JC, found identity proved on the balance of probabilities, the civil standard of proof.

On publication, the court held that posting material on a website accessible worldwide is publication, and it took judicial notice of the reach of the internet, that is, accepted it without formal proof.

RM800,000, upheld on appeal

With identity and publication established, the pleaded defences failed. In February 2014 the High Court awarded RM800,000 in damages and RM50,000 in costs. The award reflected the plaintiff’s standing, the gravity and vulgarity of the allegation, the width of publication and the absence of any apology.

On 4 December 2015, as reported by Malay Mail, a Court of Appeal panel led by Rohana Yusuf JCA dismissed the defendant’s appeal and upheld both liability and the RM800,000 award. Press reports differ on how the costs orders finally stood, so we do not state that here. Leave to appeal to the Federal Court was later refused, reportedly in 2016.

Payment took longer. Free Malaysia Today reported that on 4 December 2017, after a creditor’s petition (a step in bankruptcy proceedings) had been filed, the defendant paid about RM951,000, a sum that included roughly RM101,000 in interest.

Section 114A and other routes to a name

The Anwar case was decided on witness evidence, but claimants now have further tools. Section 114A creates rebuttable presumptions that content was published by the person whose name, photograph or pseudonym appears on it as owner, host, administrator or editor; by the registered subscriber of the network service; and by the person with custody or control of the computer.

In YB Dato’ Hj Husam bin Hj Musa v Mohd Faisal bin Rohban Ahmad the Court of Appeal held that a blogger’s bare denial of authorship does not rebut the presumption. In Tong Seak Kan & Anor v Loke Ah Kin & Anor the High Court applied section 114A(2) after blog posts were traced through internet-protocol and subscriber information. In Thong King Chai v Ho Khar Fun an email sent from the defendant’s address and a post on the defendant’s Facebook account were presumed to be the defendant’s.

Where the author is wholly unknown, a claimant may ask the court under the Rules of Court 2012 for discovery, including before a suit is filed, so that those who hold identifying records can be ordered to disclose them.

Online anonymity, in short, is a practical obstacle, not a legal shield. Identity can be proved by people the author told, by photographs and admissions, by subscriber records and by the statutory presumptions. Once a presumption applies, simply saying that it was someone else is not proof.

Practical takeaways on pseudonyms, shared devices and evidence

• A pseudonym, a fake profile or a SIM card bought for the purpose is not protection. Ordinary evidence, such as what you told other people, can identify you.

• If your name, photograph or handle is on the account, or the internet line or Wi-Fi is registered to you, the law may start from the position that you published the content. You must then prove otherwise.

• Secure your accounts and your Wi-Fi. If you are hacked, report it at once and keep the report.

• Page and group administrators should note that section 114A(1) mentions administrators. We are not aware of a Malaysian decision holding a WhatsApp group admin liable merely for holding that role, so how far the presumption reaches there is not settled.

• If you are the target, capture the addresses of the pages, timestamps and screenshots immediately, before anything is deleted.

• Judgment debts attract interest, and unpaid judgments can lead to bankruptcy proceedings.

Status of the related 2026 suit

The separate suit by Lim Guan Eng and his son against the same defendant is not final. Malay Mail reported that on 19 May 2026 the High Court (Roslan Mat Nor J) ordered the defendant to pay RM200,000 to Lim and RM80,000 to his son, plus costs, over Facebook posts made on 14 March 2020; that an appeal was filed on 2 June 2026; and that a stay was refused on 17 September 2026. As at 19 September 2026 the appeal is pending. We express no view on its merits.

Authorities and sources

• Datuk Seri Anwar bin Ibrahim v Wan Muhammad Azri bin Wan Deris [2014] 9 MLJ 605; [2014] 3 MLRH 21 (High Court, Kuala Lumpur)

• YB Dato’ Hj Husam bin Hj Musa v Mohd Faisal bin Rohban Ahmad [2015] 3 MLJ 364 (Court of Appeal)

• Tong Seak Kan & Anor v Loke Ah Kin & Anor [2014] 6 CLJ 904 (High Court)

• Thong King Chai v Ho Khar Fun [2018] 1 LNS 374 (High Court)

• Evidence Act 1950, section 114A; Defamation Act 1957, sections 8 and 9; Rules of Court 2012 (discovery)

• The Edge, report of the High Court judgment, 2014; Malay Mail, 4 December 2015; Free Malaysia Today, 4 December 2017; Malay Mail, 17 September 2026

This article is general legal information only and is current as at 19 September 2026. It is not legal advice and does not create a solicitor-client relationship. Court decisions may be appealed and the law may change; please seek advice on your own circumstances. — Chris & Partners, Advocates & Solicitors