The complainant does not have to prove actual damage. He or she only has to demonstrate exposure to the risk of one or more of these four results of the publication.

The complainant must prove that the statement complained of was published, that it bore the untrue — libellous — meaning alleged, and that he or she was identifiable as the subject of the statement.

The journalist, programme maker or broadcaster sued for libel has three possible lines of defence:

1. that the statement complained of is true (justification);

2. that the statement complained of is fair comment on a matter of public interest; and

3. that the statement falls under one of the exemptions to defamation (eg privilege.