Where published material juxtaposes a plaintiff's name with photographs of known criminals, the identities of those criminals and their criminal histories are not so notorious as to form part of the general knowledge of the ordinary reasonable reader, and must be pleaded and proved as extrinsic facts for a true innuendo claim. An imputation that a plaintiff is a 'Melbourne criminal' may be too vague where the pleading does not specify whether the plaintiff is alleged to be associated with crime generally or likened to specific criminals. True innuendo imputations that a plaintiff is one and the same person as two different individuals are logically unsustainable where the published material depicts three different faces.
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