Complaints to police alleging criminal conduct by third parties are not absolutely privileged under Australian law, following Mann v O'Neill, and the English extension in Taylor v Director of the Serious Fraud Office does not apply. The implied undertaking on documents produced under subpoena by strangers to litigation may be released where the document is the very foundation of the plaintiff's case and the action is against the author rather than the producing party. A company is not liable for defamation published on its letterhead by its sole director where the publication does not advance the affairs of the company.
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