A publication made in the course of a public controversy that raises government and political matters does not automatically attract the extended defence of qualified privilege; the publication itself must be characterised as concerning government and political matters. In assessing malice in the context of public campaigns, care must be taken to distinguish between the consequence of successful opposition and the purpose of the publisher, and the motives of one campaign participant cannot be attributed to another merely because they participated in aspects of the same campaign. Reliance on evidence given in court proceedings may constitute reasonable grounds for believing an imputation to be true for the purposes of the Lange reasonableness requirement.
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