In defamation proceedings where a fair comment defence is raised, the factual substratum upon which the comment is based must be identified by reference to the thrust of the article as a whole, not by an unduly narrow reading of particular passages. Where an article deals generally with employment conditions across a class of employees, the relevant facts for the fair comment defence extend to the conditions generally, not merely to a single example cited in the article. Employment contracts and related documents are discoverable where they relate to the general factual assertions underlying the comment.
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