A Compendium of the Law of Torts Specially Adapted for the Use of Students

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J. , in Jloi/al Aquarium, ije. Co. V. Rarkinson, (1892) 1 Q. B. At p. 451.
(o) Hoijal Aquarium, ^r. Co. V. Parkiuson, (1892) 1 Q. B. 431.
(/>) See pp. 112-113, 121—122, i)i/ra.
(q) For the arjruiTient. S iti support of tliiH contention, sec the Author's " Princii)leH and rractico of the Law of Libel and Slander, " 2nd cd. P. 108, William Clowes & Sons, Limited, London, 1897.
112 LAW OF TORTS.
thing- done in the courso of any naval or military proieeding is absolutely privileged. Thus, any de- f
...amatory statement made before a naval or military court-martial, no matter how untrue and malicious, is protected {>•). Similarly, no action lies in respect of such a statement in a report made in tlie course of military or naval duty (. S). For reasons of public policy the same protection would, no doubt, be given to anything in the nature of an act of State, c. G. , to every communication relating to State matters made by one minister to another or to the Crown {t) .
B. The following are the cases of qualified privi- lege, in which proof of malice enables plaintiff to succeed : — ■ 1.


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