The requirement that reports of court proceedings be accurate to attract qualified privilege applies only to the specific category of privilege for reports to the general public, and does not apply as an additional requirement to the reciprocal duty and interest category of qualified privilege. A specialist newsletter publisher who has accepted subscriptions to provide information on a topic of public interest (such as occupational health and safety) has a moral and legal duty to publish matters of significance on that topic, supporting the existence of qualified privilege. Material in a privileged communication that provides context for the privileged subject matter is sufficiently connected to the privileged occasion unless it is truly unconnected with the subject matter.
The full text is available to signed-in members, including the 11 later cases that cite this judgment.
3 of the 11 citing cases carry a classified treatment. How each court treated it is available to signed-in members.