The pleading requirements for injurious falsehood are the same as for libel and slander: the precise words of the impugned statement must be set out with reasonable certainty, together with the identity of the speaker, the audience, and the circumstances. A plaintiff's inability to access documents recording the precise words is not an answer to this requirement; a plaintiff cannot overcome the objection by guessing at the words. Additionally, a pleading of injurious falsehood must allege a precise causal chain between the false statement and the loss suffered, and it is impermissible to mix up different allegations of loss relating to different statements with a generalised conclusion of causation.
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