Publication is necessary for defamation˳ Publication must be intentional or negligent˳ Here publication does not mean giving the publicity but to make the statement known to other person than the person defamed˳
If a defendant has committed defamatory statement only to the plaintiff and to none else then it shall not amount to defamation˳ If he of his own will hands it over to someone else who reads it, it will be publication by himself and, therefore defendant cannot be responsible, but where he is under a duty to send it to some other person, defendant is liable˳
In Pullman v˳ Hill, [(1891) 1 OS 524, the plaintiff dropped a letter in an open card containing defamatory matter, which is likely to be read by somebody else˳ It was held that it amounts to publication˳
In Theaker v˳ Richardson, [(1962) 1 All ER 229] it was held that to send something via telegram or postcard that could be read by others can be claimed as publication˳
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, then this amounts to publication˳
In Sadgrove v˳ Hole, [(1829) 10 BRC 263] the defendant sent to a third person a post card containing a defamatory statement relating to the plaintiff, but plaintiff’s name was not mentioned, and no stranger unacquainted with the circumstances would have known to whom it referred˳
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