Reciprocity of interest or duty between publisher and recipient is not a universally necessary ingredient of the defence of qualified privilege; the presence or absence of such reciprocity is a relevant factor but not an essential requirement. A Federal Member of Parliament may enjoy qualified privilege when publishing defamatory statements to the general public about persons involved in a major political controversy, provided the publication is honestly made in the discharge of a public duty or in the protection of a legitimate interest. Strong, intemperate and extravagant language is indicative of indignation and conviction rather than malice where the defendant honestly believed in the truth of the statements and was motivated by a desire to inform the public.
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