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When the Supreme Court held in New York Times Co v Sullivan' that there is a conditional privilege attached even to false statements about a public official 

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England and Wales thrive on being a democratic society, promoting the need for equal Although, within this, freedom of expression is a fundamental right, this is Despite attempts to control this through the reform of defamation laws, it

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While the doctrine may hold more sway in cases based in the US than in England and Wales, it has arguably affected influential judicial decisions in defamation 

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For the purpose of examining the potential for the civil law achieving the desired ends, three different approaches (the UK, Ireland and the US) are chosen and the  

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