Unsolicited publication of defamatory matter to media outlets does not attract common law qualified privilege merely because the subject matter is of public interest; the journalists must have a specific interest or duty beyond the general interest of the public. A finding of malice defeating qualified privilege must be based on analysis of the defendant's belief in the truth of all defamatory statements, not just those relating to one disputed event. Where multiple imputations arise from distinct factual events, the defence of truth must be separately considered for each.
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