A book-length publication that presents its central allegations in a factual narrative style — with a title claiming to tell 'the true story', end notes citing sources, and a narrative structure presenting events as factual accounts — will not support a fair comment defence, even where the author could not have had direct knowledge of the events described. Each fact stated in a publication upon which an asserted comment is claimed to rest must be made good, even if comparatively unimportant. The question whether the respondent's Notice of Contention (objective fairness of the comment) would have succeeded was left open.
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