Recklessness in publishing defamatory matter during an election campaign does not defeat qualified privilege unless it amounts to wilful blindness or is accompanied by evidence of an improper state of mind such as anger, hatred, bias or unreasoning prejudice. The occasion of qualified privilege in election campaigns extends to statements by candidates about non-candidates who have actively entered the political debate by campaigning against the candidate. A defendant's sworn statement that they believed information received from a parliamentary colleague to be well grounded and accurate, where there was no reason to doubt the colleague's honesty, undermines a finding of wilful blindness.
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