A model of media freedom for Ireland and Article 40.6 gets some clout?
In the history of Irish Freedom of Expression jurisprudence there has never been any explicit judicial recognition of one model of media freedom as informing judicial decision-making or legislative drafting. It is arguable that a failure to recognise a single formula for media freedom has done disservice to the free expression of media organs especially when confronted with the tort of defamation – freedom of expression often having to bow in favour of the right to a good name.
In Ireland, “the law starts from the premise that the maker of a disparaging statement is liable and [it] starts therefore with an easily established and potentially immense range of liability” hence, freedom of expression “occupies an inferior position in the lexicon of Irish values”, one of those values being the right to a good name.
With the introduction of new Defamation and Privacy legislation in Ireland it is envisaged that the developments of both the Irish and European Courts will be reflected in the modernising legislation. Accompanying this development, it would be hoped that the new legislation reflects a robust commitment to a model of media freedom. With particular reference to defamation, a liberalising trend regarding that realm of the law, on an international scale has become discernable over the past twenty of years. Undoubtedly international treaties such as the European Convention on Human Rights (ECHR), the Universal Declaration of Human Rights (UDHR) and the International Covenant on Civil and Political Rights (ICCPR) are answerable for this trend. The Defamation and Privacy Bills 2006 could be seen as symptomatic of Ireland honouring its commitment to the European and International covenants to which it has subscribed.
This essay will endeavour to decipher the model of media freedom that is evident in the recent case law of the Irish Courts (under the influence of the Strasbourg jurisprudence). Secondly, it will consider the provisions of the new legislation and identify whether or not the new legislation equally reflects such developments. Finally, it will consider whether recent decisions such as Leech v. Independent Newspapers may be leaning towards extending a more generous hand to media organs in their defence of free expression than is currently enshrined in the new legislation.
Before applying the theories of freedom of expression of media organs to the Irish context it is appropriate to “set-the-scene” of Media Freedom in general Ireland:
Article 40.6.1°of Bunreacht na hEireann guarantees freedom to express opinions and convictions , subject to considerations of public order and morality :
The State guarantees liberty for the exercise of the following rights, subject to public order and morality:
i. The right of the citizens to express freely their convictions and opinions.
The education of public opinion being, however, a matter of such grave import to the common good, the State shall endeavour to ensure that organs of public opinion, such as the radio, the press, the cinema, while preserving their rightful liberty of expression, including criticism of Government policy, shall not be used to undermine public order or morality or the authority of the State.
The publication or utterance of blasphemous, seditious, or indecent matter is an offence which shall be punishable in accordance with law.
Traditionally, the Irish Courts’ response to pleas for vindication of freedom of expression has been one of characteristic Common Law scepticism. Indeed, it is clear from the language of the Article that the emphasis in Irish Law is on the limitations to the right of freedom of expression rather than on the right itself. Citizens are supposed to have the right to express “freely” their convictions and opinions, yet how can they “freely” exercise this right if it is subject to public order and morality, as stated at the very beginning of the Article?.
Furthermore, “public order and morality” are not the only considerations which work to qualify this right in practice, for example, injury to a person’s good name or their privacy will also place limitation on the exercise of Article 40.6.1° It “includes enough qualifications to leave in some doubt the commitment of the Constitution to full, democratic, freedom of thought and freedom of speech”. The Press is specifically mentioned in Article 40.6. 1° (i), but in a type of parenthesis. The “rightful liberty” of the press, which includes criticism of government policy, has to be preserved but “the education of public opinion” is so important that the onus is on the State to ensure that the organs of public opinion are not used to undermine the important values of public order, morality etc. As McGonagle underlines; “The formulation is unfortunate and does little to secure media freedoms. The result has been that, until recently, the Courts did not pay much attention to the guarantee of freedom of expression particularly in the media context.
Other rights were allowed to take precedence over it. Long-standing common law rules, such as defamation and contempt of court were allowed to operate unperturbed”. There are relatively few Irish judicial decisions where Article 40.6.1 (i) is invoked in support of media freedom, examples of the Court considering that “..the matter of the freedom of the press and of communication ….cannot be lightly curtailed” include X v. RTE , AG for England and Wales v. Brandon Book Publishers and Cullen v. Toibin .
McGonagle points that in Ireland, the Constitutional statement on freedom of the press has been considered too weak to have any real impact on the common-law approach to defamation. She contrasts this with the approach of the United States “..with its strong First Amendment commitment to freedom of the press..” which has “..dominated and reshaped the tort of defamation in that country.” In Ireland, as a consequence of following the lead of Britain, which does not have a Constitutional guarantee of freedom of expression, the tort of defamation in Ireland operated in a manner (as in Britain) that virtually ignored the existence of our constitutional values protecting freedom of expression. McGonagle points that “there was an underlying assumption that the common law of defamation partly codified in the Defamation Act, had got the balance right”.
This opinion was ill-informed. Irish Law is aimed at achieving equilibrium between three Constitutionally-protected interests: Right of Freedom of Expression (Article 40.6. 1°), Right to Communicate (Article 40.3.1°) and the Right to a Good Name (Article 40.3. 2°). The Defamation Act 1961 mimics the equivalent British legislation and this has meant that Irish libel law has failed to take account of our own Constitutional values, outlined above. The Act makes no attempt to balance the three Constitutional provisions and has operated as a law that assumes that freedom of expression is a bad thing. In 1996 the Constitution Review Group asked “The essential question whether the defamation laws effect a fair balance between the right of free speech on the one hand and the need to protect individual reputations on the other?”.
The answer to their question had been provided a few years earlier by the Law Reform Commission in their Consultation on the Civil Law of Defamation 1991: “We believe that current Irish Defamation Law fails to serve each of these interests satisfactorily in many areas”. Since the 1991 Report, the jurisprudence of the Irish Courts has moved-on to take account of the influence of ECtHR jurisprudence (since it formed part of Irish Law at sub-constitutional level in 2003) and developments in the common law. In Goodwin v. Hamilton No.2 the Courts intimated that, with respect to Constitutional Rights, good name is not a “trump” card that takes precedence over all other rights. This could be seen as the first step towards a new “constitutionalising” of the tort of defamation.
This sets the backdrop to the introduction of the Defamation and Privacy Bill 2006. The Irish laws on Defamation and Privacy are long-overdue an overhaul, media law commentators such as O’Dell have highlighted the “acute need for the modernisation of Irish Defamation Law” and have criticised the delay of government in instituting this modernisation. McGonagle points that “Delay has meant that those affected by defamation, whether as plaintiffs or defendants as well as the public at large have had to soldier on under very outdated laws, drafted at a time when television was only beginning in Ireland and the Internet was not even heard of”. It is envisaged that the new Bills spell the end of, as in the case of the Defamation Act 1961, an over-reliance in decision-making by the House of Lords and the introduction of law that better-reflects Irish Constitutional mores and developments of the ECtHR. Both the Defamation and Privacy Bills 2006 have “conceptual implications” for the status of media freedom in Ireland and together, the Bills acknowledge a model of freedom of the press which has heretofore not been specifically recognised in Irish jurisprudence”.
Before discussing the model of media freedom that appears to exist in Ireland, it is first appropriate to discuss the different theories of freedom of expression and of the press advanced by various legal scholars.
The proper functioning of modern, participatory democracy requires that the media be free, active, professional and enquiring.
Barendt discusses four main rationales for the importance of freedom of speech – the argument from truth, the argument from self-fulfilment and self-development, the argument from democracy and the argument from freedom from state coercion. Scott has highlighted the importance of not over-emphasising the discreteness of these explanations and moreover, he opines that it is important not to expect that any particular corpus of rights will reflect specific philosophies. Jacob Rowbottom contends that “the relationship between the right of expression and media freedom is complex”. He advances “three well-known justifications” for freedom of expression: The first, as discussed by Barendt, justifies freedom of expression as essential to a person’s autonomy and self-fulfillment.
The second justification is the “market place of ideas” rationale : “..that minimal government regulation will allow robust debate between citizens that is most likely to lead to the truth”. This echoes Milton’s idea in Areopagitica in the 17th century when he declared “Let Truth and Flasehood grapple; whoever knew Truth put to the worse, in a free and open encounter?”. The third justification highlights that freedom of expression is a necessary component of a democratic government. These theories of freedom of expression all overlap and have each been criticised in turn. Rowbottom also points to instrumental justifications such as the media’s public function in the dissemination of information as supporting media freedom – “It is very largely through the media … that they (the public) will be so alerted and informed. The proper functioning of modern participatory democracy requires that the media be free, active, professional and inquiring”.
However, any argument in favour of an uninhibited press must be accompanied with the reminder that the media exercises their freedom in a manner that is different from that of individual speakers and sometimes mass media will use its controlling force to undermine individual’s rights to free expression. On this point, Rowbottom quotes from Democracy in the Mass Media where Judith Litchenberg opines that “Unlike freedom of speech, to which certain aspects of which our commitment must be virtually unconditional, freedom of the press should be contingent on the degree to which it promotes certain values at the core of our interest in freedom of expression generally”. This is redolent of the approach to Article 10 ECHR taken by the Strasbourg Court in Jersild v. Denmark where the special role of the media as a “public watchdog” was afforded protection.
It is now proposed to decipher the model of media freedom which appears to have been embraced by recent jurisprudence of the Irish Courts and the new legislation.
A Democratic Model of Media Freedom?
Despite the lack of any explicit judicial recognition, it is arguable that in recent years the Irish Courts have moved towards recognising the Democratic Model of media freedom as being the leitmotif of Defamation and Privacy Law. This idea is embodied in the new reforms in the law. The precepts of the democratic model are best illuminated when placed in contrast with the free market model of media freedom:
The free market model embraces the Milton Ideal of the Free Market of Ideas where theories succeed or fail on their own merits. It was advocated by Justices Holmes and Brandeis in Abrams v. US where is was declared that“..[t]he best test of truth is the power of the thought to get itself accepted in the competition of the market.” The seminal decision of New York Times v. Sullivan provided that the defamation suit taken by a public figure was only sustainable when actual malice on the part of the Defendant was found. The highlight’s the free-market model’s focus on the honesty of the person making the statement rather than the truth of the statement.
In contrast, the Democratic Model envisages a pedagogical role for the Media. It views the Sullivan-Style immunity for untrue statements as damaging to democracy, the once “free” market becomes polluted with false information and this “licence” for false information is viewed as inimical to robust, informed debate by citizens on matters of public interest. This model for press freedom has been embraced in Canada, Australia, New Zealand and in the House of Lords.
Irish jurisprudence never truly favoured any one model. The only important role of the media that has been recognised is that of “public watchdog”(Irish Times v. Ireland ). However, Article 40.6. 1° describes the media as “organs of public opinion” and recent decisions on defamation and privacy appear to subscribe to the notion of the media as a vital facilitator of citizen’s debate also. Hence, it is reasonable to conclude that the Democratic Model has most influence on Irish Law:
Recent high profile cases such as Hunter v. Duckworth  IEHR 81 and Leech v. Independent Newspapers  IEHR 223 are testimony to the Democratic Model informing judicial decision-making. In Hunter, O’Caoimh J. endorsed the decision of Nicholls J. in Reynolds v. Times Newspapers – liberalising the law of defamation and extending the Qualified Privilege Defence, applying the “Reynolds-Style” privilege to a publication that the Courts deem to be the product of responsible journalism. He noted with approval Nicholls J.’s list of non-exhaustive factors that indicate responsible journalism as well as his focus on the “extent to which the subject the subject matter is of public concern”.
The case concerned two members of the “Birmingham Six” who claimed they had been libelled by the author and publisher of a booklet entitled “The Birmingham Six and Other Cases: Victims of Circumstances”. The plaintiff’s claimed the inference or innuendo contained in the booklet was tantamount to depriving them of their innocence, despite the quashing of their convictions. The defendant relied on his Article 40.6.1 and 40.3 rights to freely express his opinions. Despite O’Caoimh J’s strong endorsement of Nicholls J’s decision in Reynolds he allowed another Article 40.3 right to take precedence over free speech.
He emphasised that “reputation is an important part of the dignity of the individual” to the extent that he would weigh the balance in favour of reputation in this case. Despite advocating Nicholls J’s approach, O’Caoimh J. was adamant that while the tort of defamation could act as a disincentive to freedom of expression, so to would any law that tempers that right. The legitimate “end” of reputation justified the “means” of restricting freedom of expression.
The Hunter case provides a good example of the democratic model of freedom of expression asserting itself in Ireland to the extent that O’Caoimh J. displayed enthusiasm for the ten- point indicia of responsible journalism as well as the degree to which a story is of “public concern” of Reynolds and these factors place emphasis on the accuracy and veracity of a published story – hence, it falls into the mould of a democratic model. However the decision can only stand as obiter in this context as the defendant employed the Reynolds decision to support a different argument – “.. the defendant wanted to protect his opinion and relied on the Reynolds expansion on libel defences by analogy in support of his proposition that his opinion should be constitutionally protected, not that he should be entitled to rely on Reynolds-privilege.”
The case of Leech  is a better reaffirmation of the expansion of libel defences in Irish Law. ”. Charleton J.’s judgement gave more leeway to media on the libel defence. It copper-fastens the Reynold’s defence of reasonable publication/responsible journalism in the public interest to libel actions in Irish Law but Charleton J. also wisely “injected some common sense eschewal of technicality, directing attention and analysis away from the ten criteria to the underlying questions of public interest and responsible journalism”. The Reynold’s defence has been heralded as groundbreaking but subsequent case law revealed that it was being applied in a haphazard manner and had little effect on decisions at First Instance.
Cases such as GKR Karate v Yorkshire PostLtd, Grobbelaar v News Group Newspapers and Al-Fagih v HH Saudi Research & Marketing (UK) Ltd are illustrative of this fact. It was only with the judgement in Jameel v Wall Street Journal that a welcome clarification was provided to some of the unrealistic attitudes displayed by the judiciary in applying the Nicholls J. ten- point indicia It ‘breathes life into Reynolds, restating, and possibly liberalising the Reynolds approach.’ It was precisely this attitude that Charleton J. adopted in Leech. He recognised the ten point criteria as a useful guide but not as a determinative tool.
He placed the emphasis on the questions of the “public interest” in the story and whether responsible journalism had been displayed by the defendant. O’Dell welcomes Charleton J’s adoption of the Jameel ratio as first and foremost and his demotion of the non-determinative Reynold’s criteria to a secondary place. The judgement further promises liberalising defamation law in its treatment of media’s libel defences as a “public interest defence”.Throughout the judgement, Charleton J. repeatedly asserts the “public interest” (rather than “public importance”) of a publication
“I would rule that a public interest defence can arise where the subject-matter of a publication be it an article or radio or television report, considered as a whole was a matter of public interest… I would rule as well that there is a professional duty on the part of journalists to both seek out information that is of a public interest and to impart it to the public and that while that is a matter of professional skill and training, that is also a matter of responsibility”.
This statement is significant because it asserts that in Irish Law, the press may publish something that is wrong (or not provably right) and they will not be penalised provided they have followed good practice. It levels the pendulum between the right of the public to be informed and the right to reputation. This is affords a very wide defence and it is debatable whether such a wide interpretation would be carried through in the new legislation or whether it would even survive a Supreme Court appeal. While as it stands, Leech remains a fragile precedent, it is a welcome step in recognising a model of media freedom which echoes ECtHR decisions such as Schwabe v. Austria and Bergens Tidende v. Norway.
It is to be noted also that the scope of the Constitutional guarantee of media freedom has also been connected to the question of privacy and the public interest as outlined in the recent decision of Cogley v. RTE. In his decision, Clarke J. emphasised the importance of balancing the protection of privacy against the Constitutional requirement “that there be a vigorous and informed debate on issues of importance”. The public interest in broadcasting the programme in question eclipsed the fact that the information was unlawfully obtained and infringed the privacy rights of individual residents of an Irish nursing home.Clarke J. also warned that the public interest would have to be very significant to warrant interference with the Right to Privacy. The Court must be conscious of “..the fact that “It is all too easy to dress up very many issues with an exaggerated and unreal public dimension”.
The fact that the public interest is a prerequisite for Constitutional protection again nods to a democratic conception of press freedom.
The Defamation Bill 2006: (published by Irish Government, July 2006)
The new Irish Defamation Bill revises part of the law on defamation in Ireland as well as updates the law to reflect the developments in Irish and ECtHR jurisprudence. It is submitted that its provisions also reflect a democratic model of media freedom. Section 16 of the Bill places the defence of qualified privilege on a statutory footing and more innovatively, the Bill also provides a separate new defence of “fair and reasonable publication on a matter of public importance” in Section 24. This defence, contained in Section24(1) reflects Nicholls LJ’s approach in Reynolds. Section 24(2) contains a list of factors reminiscent of Nicholls LJ’s criteria for responsible journalism. The emphasis on accuracy in s.24(2) rather than pure participation in public debate is indicative of the democratic model. Schedule 2 of the Bill refers to the “public interest” being served by “..ethical, accurate and truthful reporting by the Press” this again echoes the democratic model. The defence contained in Section 24 has been criticised by academic commentators such as McGonagle and O’Dell who notes that:
“ The current text of the defence is so hedged that it invites the kind of narrow and rigid parsing that is likely to render it dead on arrival, a statutory dead letter even on the day of its enactment’ .
It is for this reason that O’Dell welcomes the very wide approach taken by Charleton J. to media’s libel defences in Leech.
It is submitted that the Leech decision goes even further than the legislative text of Section 24(1). Section 24(2) does not provide a realistically workable defence of fair and reasonable publication. Indeed, it is not desirable that section 24(2) would be invoked in the same rigidly formulaic fashion as the Reynold’s indicia (the inspiration of section 24(2). It would be advisable to recast this section in the mould of Charleton J’s assertions in Leech which advocated the Jameel “correction” of the Reynold’s defence. The question then remains as to how much of the Leech ratio would survive the enactment of the Defamation Bill. O’Dell underlines that if the decision had a constitutional basis, it would be harder for the Bill’s enactment to dilute Leech’s effect on the law.
Privacy Bill 2006:
It is submitted that the Privacy Bill 2006 echoes the Defamation Bill in that it protects media freedom exercised within the parameters of educating citizens on matters of public importance. The newly- created Tort of Violation of Privacy in Ireland indicates that a free market regime of publication does not exist in Ireland. Tort is actionable without proof of special damage and “privacy” is within the parameters of “privacy that is reasonable in all the circumstances having regard to the rights of others and the requirements of public order, public morality and the common good”
Certain actions that “shall” amount to privacy include subjecting a person to surveillance, disclosing information or documentation obtained by surveillance without the consent of the individual for financial gain, disclosing diaries etc or harassment. It is to be noted that the Irish LRC were in favour of separate categories of torts of invasion of privacy rather than the “rolled-into-one” approach mentioned above. Section 4 demands that the Court has regard to a person’s office/position when determining their expectation of privacy. Section 5(e) defends an “act of newsgathering” for a subject of public importance that is “fair and reasonable” in all circumstances.
There may be some problematic implications of the Bills as regards the required “public importance” and “fair and reasonable” character of publications. Judges are obliged to review a publication for its “public importance” but neither Bill gives any definition or guidance on this term.
From Cogley, it could be submitted that the term would be afforded an expansive interpretation as that case concerned private individuals – the judgement did not insist that the publication be limited to publication concerning elected officials only.
Judges recoil from being arbiters of the truth but it is suggested by that they would probably adopt a procedural approach when examining the investigation and accurate presentation (or not) of information to decide whether there was a “fair and reasonable” publication within the meaning of both new Bills. The adoption of a Press Code as suggested in Section 24(2) Defamation Bill would aid in such adjudication. Without such a guideline, this might have dangerous implications for source protection – as considered in recent High Court decision against the Irish Times.
That said, it is contended that, while the judges in Mahon held that forcing disclosure of sources in that case was justified under Article 10(2) ECHR and necessary to preserving integrity and confidence in the Tribunal process, the decision must be welcomed as affording strong support to press freedom despite the fact that the decision was quite damning of the conduct of the Irish Times. Dicta from the judgements of President of the High Court, Richard Johnson and Kelly J. and O’Neill J. are clearly informed by the importance placed on press freedom by the ECtHR. The judgement acknowledges “..the public interest in the preservation from disclosure of journalistic sources, as an essential prerequisite of a free press in a democratic society?”, a principle not recognised as robustly before.
The judgement also endorses “..the critical importance of a free press as an essential organ in a democratic society. An essential feature of the operation of a free press is the availability of sources of information. Without sources of information journalists will be unable to keep society informed on matters which are or should be of public interest. Thus there is a very great public interest in the cultivation of and protection of journalistic sources of information as an essential feature of a free and effective press.”
While the provisions of the Defamation and Privacy Bills 2006 are as they stand, imperfect and the law in Ireland is not yet entirely settled (as evinced in the contrast between the decisions in Mahon v. Post Publications and the grounds of the Supreme Court Appeal (announced November 9th) to be taken by the Irish Times against the Mahon Tribunal.) the modernisation and liberalisation of Irish media freedom which they envision is to be commended. They form part of the movement of Irish law towards a democratic model of media freedom. This casts off the shackles of traditional I,rish, common-law scepticism towards freedom of expression.
The change has already been signalled in recent decisions of the Irish Courts in Cogley and Leech. However, the success of the libel defences in the new Defamation Bill – whether or not they are recast in the language of Leech – and the defences in the Privacy Bill, will be largely dependant on individual judges’ willingness to endorse a democratic model of media freedom. It is submitted that Fennelly J’s recent resounding endorsement of freedom of expression gives readers reason to be hopeful on this point : “The media are not required to justify publication by reference to any public interest other than freedom of expression itself. They are free to publish material which is not in the public interest. I have no doubt that much of the material which appears in the news serves no public interest whatsoever. I have equally no doubt that much of it is motivated and perfectly permissibly so, by the pursuit of profit. Publication may indeed be prompted by less noble motives”.
Reynolds v. Times Newspapers  2 AC 127.
Jameel v. Wall Street Journal  1 AC 359
McCartan v. Times Newspapers 2 AC 180
GKR Karate v Yorkshire Post Ltd 1 WLR 257
Grobbelaar v News Group Newspapers  2 All ER 437.
Al-Fagih v HH Saudi Research & Marketing (UK) Ltd  EWCA Civ 1634.
Murphy v. IRTC IR12
Goodwin v. Hamilton No.2  3 IR 307.
AG v. Paperlink  ILRM 348
Hunter v Gerald Duckworth & Co Ltd. (unreported High Court 31 July 2003 O’Caoimh J).
Leech v. Indepedant Newspapers IEHR 223.
Cogley v. RTE  4 I.R. 79.
Mahon v. Post Publications  IEHC 307,  IESC 15.
Judge Mahon and Others v Keena and Kennedy,  IEHC 348.
Murphy v. Ireland (2004) 38 EHRR 13.
Jersild v. Denmark (1995) 19 EHRR 1.
Schwabe v. Austria (1992) Series A No 204-B.
Bergens Tidende v. Norway (2001) 31 EHRR 16.
Thorgeirson v Iceland (1992) 14 EHRR 843.
Other Common Law Jurisdictions:
Abrams v. US 250 US 616 (1919)
New York Times v. Sullivan 376 U.S. 254 (1964)
Lange v Atkinson  3 NZLR 385.
Lange v. ABC (1997) 147 A.L.R. 96.
Hill v. Church of Scientology  2 S.C.R. 1130 AT 1183 dicta of Cory J.
McGonagle, Marie, Media Law, (2003)2nded. Thompson/Roundhall.
Fenwick and Phillipson, Media Freedom and the Human Rights Act,(2006) Oxford University Press.
Journals cited :
Kelly, Deirdre, Bearing Falsewitness against your neighbour: The Evolution, perils and possibilities of the development of Qualifies Privilege in Defamation Law (2007) 7UCDLR109.
K Beattie, ‘New Life for the Reynolds ‘Public Interest Defence’? Jameel v Wall Street Journal Europe’ (2007) 1 Euro Human Rights L Rev 81.
I Loveland ‘The Ongoing Evolution of Reynolds Privilege in Domestic Libel Law’ (2003) 14 Entertainment L Rev 178.
Hooper ‘The Importance of the Jameel case’ (2007) 18(2) Entertainment L Rev 62.
B Docherty ‘ Defamation Law: Positive Jurisprudence’ (2000) 13 Harvard Human Rights J 12.
Wildhaber, The Right to Offend, Shock or Disturb? (2001) 36 Irish Jurist.
McDonald, Towards a Constitutional Analysis of non-media qualifies privilege” (1989) 11 DULJ.
O’Dell, Does defamation value free expression?  12 DULJ at 62.
McGonagle, Marie, Reforming Media Law in Ireland:Part 1: Defamation and Privacy, (2006) Communications Law ,11(6), 195-200
Rowbottom, Jacob, Media Freedom and Political Debate in the Digital Era (2006)MLR 69(4) 489-513
O’Neill, Corporate Freedom of Expression (2005) 27 DULJ 185
Bonnington Reynolds Rides Again’(2006) 11 Communications L 147
Hooper The Importance of the Jameel case (2007) 18(2) Entertainment L Rev 62
Loveland The Ongoing Evolution of Reynolds Privilege in Domestic Libel Law (2003) 14 Entertainment L Rev 178, 179.
Cram, Reducing Uncertainty in
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