In defamation proceedings where the plaintiff is not named in the publication, the defendant bears the onus of proving that the group of readers capable of identifying the plaintiff was limited to those with a sufficient interest supporting qualified privilege. There is no rigid rule requiring the plaintiff to call evidence from readers who lacked such an interest; the court may draw inferences from ordinary experience. The question of how an unnamed plaintiff affects the scope of qualified privilege defences and damages quantification remains open for determination in an appropriate case.
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