Where a defamatory publication does not name the plaintiff but provides sufficient identifying details, the publisher may be liable for publication to readers who ascertain the plaintiff's identity by accessing readily available online sources such as a school or organisation's website, even though the identifying information was acquired after reading the article. The question of whether readers identified the plaintiff is one of fact and degree, and the strict Grappelli requirement that identifying facts be known at the instant of reading does not apply where the publication is defamatory on its face and the only question is identification. The question of whether reasonable foreseeability of identification is a sufficient basis for liability was left open.
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