Publication is vital for defamation. Publication must be intentional or negligent. Here declaration does not drive giving the publicity but to make the announcement known to new person than the person defamed.
If a defendant has operational defamatory avowal by yourself to the plaintiff and to none else later it shall not amount to defamation. If he of his own will hands it more than to someone else who reads it, it will be publication by himself and, consequently defendant cannot be held responsible, but where he is out cold a commitment to send it to some new person, defendant is responsible.
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In Pullman v. Hill, [(1891) 1 OS 524, the plaintiff dropped a letter in an obtain into card containing defamatory matter, which is likely to be salutation by somebody else. It was held that it amounts to message.
In Theaker v. Richardson, [(1962) 1 All ER 229] it was held that to send something via telegram or postcard that could be entre by others can be claimed as message.
In Delacroix v. Thevenot, [(1817) 2 Stark 63], ii was observed that if a person knowingly sends something in writing to defame a person in a closed envelope that it will be opened by someone else, as well as this amounts to message.
In Sadgrove v. Hole, [(1829) 10 BRC 263] the defendant sent to a third person a late buildup card containing a defamatory statement relating to the complainant, but petitioner’s say was not mentioned, and no stranger unacquainted taking into account the circumstances would have known to whom it referred.
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