Knowledge that a defamatory statement is untrue is ordinarily conclusive of an improper dominant purpose defeating qualified privilege, without the need to identify the specific ulterior purpose. A plaintiff relying on the knowledge of falsity conclusivity principle should plead and particularise the allegation of knowledge of falsity, but failure to do so may be overcome where the trial was conducted on that basis without objection. It is not an independent element of the cause of action for defamation that the imputation reach a minimum level of seriousness.
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