In reply to a defence of qualified privilege, the preferred pleading is that 'the publication of the matter complained of was actuated by an improper motive'. Where the plaintiff relies on the defendant's knowledge of falsity (or wilful blindness equated with knowledge), it is unnecessary to identify the specific improper motive. In all other situations, the plaintiff must identify the improper motive and provide particulars of the facts and matters relied upon to establish the relevant state of mind. Particulars of improper motive must be assessed as a whole, not by examining each particular in isolation to see whether it independently establishes knowledge of falsity. Remoteness in time of evidence relevant to state of mind goes to weight, not admissibility.
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