Sangare v NT

[2018] NTCA 10

NT Court of Appeal

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Interrogate

Catchwords

1. Defamation
2. › Defences
3. › Qualified privilege
4. › Statutory qualified privilege
5. › Reasonableness of conduct in publishing
6. › Whether publication to Minister by Departmental employees reasonable in the circumstances
7. › Defamation Act (NT), s 27
1. Defamation
2. › Defences
3. › Qualified privilege
4. › Common law qualified privilege
5. › Reciprocity of duty and interest
6. › Publication by public servants to responsible Minister
1. Defamation
2. › Malice
3. › Whether publication actuated by improper motive
4. › Onus on plaintiff to prove malice
5. › Carelessness of expression insufficient to infer malice
1. Appeal
2. › Civil appeal
3. › Self-represented litigant
4. › Competency of notice of appeal
5. › Whether notice of appeal specifying questions rather than errors is competent

Quick Take

The Court held that s 27(3) of the Defamation Act (NT) does not require positive findings on all listed factors; it is a non-exhaustive guide to the reasonableness assessment.

Case Details

Citation[2018] NTCA 10

CourtNTCA

JurisdictionNorthern Territory

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Cited by2

2019Northern Territory v SangareHCA 25
2019JB & Ors v Northern Territory of Australia (No 2)NTCA 3

Relies on3

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