THE LAW OF LIBEL
WHY REFORM IS NEEDED.
im THE MEMBERS OF THE LEGIS--10 MCCffiE, PER FAVOTJII OF THE “NEW ZEALAND TIMES.' 1
(B v Mark Cohen, President New Zea- ( y land Institute of Journalists.) Two Bills dealing with the law libel are at the present time before the Legislature, and their annual appearand on your order paper must surely bo accepted as an indication that the Fourth Escate, which constitutes a not inconsiderable nor unimportant section 't the body politic, labours under distinct and serious disabilities. That the press of this colony have been knocking at the door of Parliament for the last eleven years and claiming in a constitutional manner to have their wrongs righted cannot be gainsaid, and that single fact must be accepted by all impartial minds as disclosing on th e part of the conductors of the press a deeprooted and well-founded (as I hope to show later) dissatisfaction with a state of affairs the continuance of which is hard to explain, except on one theory, viz., that Parliament (for reasons only known to itself) has so far declined to follow the lead set by the Mother of Parliaments, or to remove, as other colonial Parliaments that do not claim to be as “ advanced ” as our own ; the fetters that bind an institution which, I have the temerity to affirm, is one of the glories of our country. When the Liberal party attained to power in 1891, and there was placed at the head of the Liberal Administration a statesman who was himself a working journalist, it was thought that the time was opportune for approaching Parliament with a modest request to place the libel laws v.f New Zealand on a par with that of England, which some years before (1881 and 1888) extended protection to ‘fair and accurate” reports of legal proceedings and of public meetings. I have good reason for saying that had the late Mr Ballance not been stricken by the illness that carried him to his grave, the then demand of the press to be brought into line with their English confreres would not only have received his strong support, hut that liis influence with his Cabinet and his party would have been exerted in the direction of giving relief to the profession of which he tvas a distinguished member. It was shortly after Mr Ballance’s death that the Journalists’ Institute was formed, and one of the first acts of iv the executive was to bring under the notice of the Seddon Government the necessity for amending the libel law so as to bring it in harmony with that of Britain. The arguments that were used on that occasion must have beqn most convincing, for it is beyond question that Mr Seddon’s own Attorney-Gene-ral, with the approval of his chief, drafted in the session of 1893 a Defamation Bill, which not only codified the existing law, but gave a greater measure of relief and protection than the press . had hoped for. I believe I am speaking by the book when I say that that Bill stands a monument to the skill of _ the man who drafted it, and for luminosity and breadth of view it has rarely been equalled, certainly never excelled, in the history of our legislation. "Whether this colony of New Zealand is entitled-to the credit of formulating a measure of the kind, which has served as a beacon to other Legislatures, is not for me to say, nor will it serve my present purpose to" make such an inquiry. The honour might have been New Zealand’s, but it must be confessed—though it is sad indeed to have to make the admission—that wretched, miserable, even despicable (and I use the latter term advisedly) tactics were resorted to in more than session by a comparatively small knot of Parliamentarians, who were not above abusing the forms of Parliament to defeat a measure that was dear to the reart of its author, and which had it passed into law would have added, as it has done where exactly similar legislation has been enacted, to the responsibilities of the conductors of the press, without causing any of the terrible evils feared by those who scented in the reform a general degeneracy into unrestricted license. After Sir Patrick’s death, the same Bill was introduced into the Legislative Council by the Hon H. Feldwick, who safely piloted it through that Chamber, where it was most cordially received, and in a later year (1897), after running the gauntlet or the House, it met with -shipwreck in the committee stage over the crucial clause, about which I shall have something to say anon. Of more recent the institute have entrusted to •“t 1 ’ C arn cross, member for the Taieri, a shorter measure, which seeks merely to put on our statute book what has been the law of England for upwards of twenty years, but these efforts have agam been rendered nugatory by the US i? °L tlie forms Parliament by men who have made no secret of their deennmation to pay off old scores against certain newspapers that have incurred heir displeasures for acts of commission or omission that cannot be charged against the press as a whole. Be that as . ,lla y> the press as an institution is bewg made to suffer because some hon gentlemen have either it vendetta, against particular writers, or because
other hon gentlemen have been made to squirm under criticism that is often both forcible and free.
I shall now essay to show why the press demand relief, and in what directions. I need not waste your space, Mr Editor, nor tire the patience of my readers by setting out what is the present state of the law. That task was undertaken last month by Mr Allan, of the “Evening Post” staff, who, in an able, lucid and temperate treatise, demonstrated what were the legal disabilities of the working journalist of to-day. He showed clearly the many pitfalls that surround the editor, reporter and publisher of ’a paper that, if is to be successful, must be run on up-to-date lines. Mr Carncross’s Libel Bill, adopting, as it does, the language of the English statute, seeks to protect “fair and accurate reports” of proceedings in every law Court, and similar reports of public meetings and of public bodies of every kind whatsoever. Now, in the phrase “fair and accurate” report there is a hidden danger, the extent of which is known .only to the pressman. The Courts at Home and in the colonies have ruled there is no protection lunder these sections unless the '.reports—whether of proceedings. in law Courts or local bodies—is absolutely correct. Let me illustrate the position by my own experience, which is common to every man responsible for the conduct of a newspaper in this colony. "An important trial has been set down for hearing before one of their Honors the Judges of the Supreme Court and a jury, and in order to do justice to it, two members of the reporting staff are told off for that purpose. The man who takes the morning setting is unlikely to be present in the afternoon; or if both men are engaged note-taking by “turns,” it must often happen that the one transcribes away from and independently of the other. The one very seldom hears what the other has taken down on his note, so that conference between them on any knotty point or question that threatens difficulty is entirely out of the question. In Hie process of transcription, which is purely mechanical, the reporter fails to notice that some averment affecting the cha' ..cter of one of the parties to the litigation that has been opened by counsel had not been proved in evidence; and the damaging statement appears -■ - print without its palliative. Or take a more glaring instance, which vitally affects evening newspapers, whero everything is on the rush for the two hours immediately preceding publication. One reporter in attendance on a case in the forenoon has instructions to report fairly fully and does so, giving, in the ojiening address of counsel, some remark that is afterwards shown to affect someone else’s character; and the reporter who is put on to relieve in the afternoon, with directions to condense as much as possible, fails to catch the drift of the cross-examination which is to clear away a damaging statement, or the essence of this particular cross-examination does not appear in the second reporter’s “burn.” In any and all of the cases I have instanced, the Courts will hold that the report is not “accurate,” and the offending newspaper will be mulcted in damages. Yet none of the persons concerned in the production of the paper can, during the turmoil and bustle attendant on the production of an evening paper (and I sperk with positiveness concerning them, for I ant treading firm grotund)—particularly during the two hours immediately prior to publication, when the tension and strain are most severely felt—have the faintest suspicion of the mischief that may lurk in the “metal” before him. Let me here produce another illustration of the dangers we daily run, as exemplified in proceedings that were taken in the Supreme Court of New South Wales a few years ago. The case" was that of Kelly v. the Sydney “Telegraph” Newspaper Co., in which £IOOO damages were claimed, because that paper had published a paragraph referring to the arrest of the plaintiff on a charge of having counterfeit coin in his possession. It was acknowledged that the paragraph complained of did nothing more than summarise the circumstances of the caS9 against the plaintiff, as they transpired in the Police Court.- Mr Justice Stephen, in charging the jury, laid it down as a dictum that the law did not protect newspapers, even if the alleged defamatory matter was a correct account of what took place in a Court of justice, if by publication a plaintiff was held up to public disgrace or scandal, defamed his character, or set him before the world as a dishonest man. Counsel for the* paper (Mr B. R. Wise, K.C.), contended that the article—defamatory or not—was a correct account of what took place in the Court, and was, therefore. justifiable, but the Judge told the jury that such a contention was untenable/ He had not the-slightest hesitation in saying that the proposition could not be maintained.” The Judge possibly interpreted, the law in accordance with obsolete ideas to be found in the discredited statutes that exist in the '■statute book of New South Wales' (vide “Hansard” for July last). But we must -thank him for a valuable suggestion, which oiught not to be lost sight of by our own legislators. His "Honor, recognising bis own responsibility in laying down the law as it exists, said he 1 found very great difficulty in the way of proprietors and editors of newspapers understanding that law, and ‘Tib thought
it would be a very desirable thing—if it oould be done-—that some table of rules and regulations should be drawn up as a guide to the press as to what was right and what was wrong m snob matters.” Mr Justice Stephen Uas bit the naal squarely on the head. If the law of libel in his own colony, as well as this, were oodxied. the conductors of the press would always have before their oyes a code so plain that everyone connected with the press would realise his actual standing before the law. The Defamation Bill of 1893 supplies in every respect such “a table of rules and regulations,” and as, Mr Groom observes, is a clear exposition of the duties and privileges of the press so olear, indeed, that he who runs may rc-cui it.
It is high time that the absurdity . ■ joining the publisher and printer with an alleged libel were done away with. Neither the publisher nor printer can under any ciroumstanoes know what is in. the paper, which they never see till it is thrown off from the printing machine, the revolutions of which aie so rapid nowadays that an entire issue is thrown off before either employee can find time to make himself acquainted with its contents. You may just as Well make the machinist ans\v erable, for of a verity h© sees quite as much as the other two combined of the paper’s contents before issue. The Courts in Sydney the other day furnished a striking instance of the inconsistency of the law in this regard, in that it too often punishes the innocent and allows the actual offender to go soot free. A firm oJ Sidney printers (brothers named Rate!iffe) had contracted to print a Chinese paper, styled the “Tung Wah” for the Chinese of that city. The “Tung Wall” libelled one ! Lee, who brought action agafne fc the paper and recovered £7OO, which, of course, carried costs. The newspaper company could not satisfy the payment, and on Juno 30th the plaintiff put the Sheriff’s officers into Messrs Ratcliffe’s establishment and scld them up, lock, stock and barrel, for £4OO, sacrificing the industry of these men’s lifetime It was proved that the Ratcliffo Brothers never saw the Chinese characters which contained the libel; these were set up by Chinese compositors in a separate building; but because the Ratcliffe Brothers were the unfortunate printers whose names were in the imprint they were ruined absolutely. No wonder that members of the New South Wales Legislature were deeply stirred by such a recital of cruel wrong, and the Hon. E. W. O’Sullivan declared that his Government would at once bring down a Defamation Bill under which a repetition of such things would not he possible. It cannot be forgotten that last year, when the New Zealand Parliament. was investigating a matter in which my own paper played a prominent part, the farce was gone through of summoning to the Bar the publisher, who was less familiar with the matters that the. Goldfields Committee were investigating than the members of that committee. If there is a genuine desire to get at the truth “go fori’ those persons who are best able to assist in its elucidation. Get rid of the anachronism of joining the publisher and printer with the proprietor in libel suits; couple tho real actual offenders, those who were responsible for the libel —the proprietor and the editor—and I, for my own part, do not see why the name of the responsible editor should pot appear in bold type over the leading column of every journal in the land. In the discussion of- Mr Carncross’s Bill in the session of 1891 Mr George Fisher went the length of saying that the English newspaper proprietors were dissatisfied with the Act of 1888 and were agitating for its repeal. As far as my information goes, the senior member for Wellington only half stated the truth. That there has been much dissatisfaction with .that Act is a fact beyond dispute, but the dissatisfaction and the appeals to Parliament to amend it are due to- entirely different causes from those alleged by Mr Fisher. In the first • place, the provincial press of Britain have experienced—to their costs in many instances—the difficulty of obtaining ‘anturate” reports, i.e., verbatim reports of either Courts of Justice or of public meetings, etc., in terms of section 4 of that Act. They have found it to be absolutely impossible. even with the most careful supervision of their columns and with the employment of expert stenographers, with the condensation demanded of journals nowadays, to satisfy the “accuracy” which the law requires. An even greater grievance which, the English press labour under is that the law does not deal out, as every law should, even-handed justice. Under it the newspaper alone, is mulcted for its publication of a slander uttered in a public meeting or by the member of a publio body, though it may be capable of proof to demonstration that the report containing the alleged libel was wholly without malice on the part of the newspaper. This grievance is tersely stated in the iutrodue ion to a work on the “Law of the Pi )ss,” which Mr Fisher ought to read:—
A second grievance of, those responsible for cue publication. of newspapers is their liability to actions for publishing statements for which the original utterers either ire not liable at all or. are not made liable. For example, a public meeting of some importance is hold. One of the speakers, a responsiblo mah. whose words have weight-with
suoh as audience,makes charges against another person. The reporter’s “copy” arrives just in tinfe to be set up for the next morning’s paper, yet the editor is called on to examine and decide on the spur of the moment whether the charges publicly and deliberately made are, or are not, “public concern,” and “for the public benefit.” If he decides that the risk of suppressing these charges, and thereby perhaps defeating, th© ends of justice, is greater than that of publishing, the newspaper proprietor is probably served with a writ, and has tho trouble and expense of defending the action, while the original speaker, on whont surely the primary responsibility should rest, escapes soot. free, either because he is not legally liable—there being no proof of special damage—or because the newspaper proprietor is a better mark for damages.
The English press, through their accredited mouthpieces, do not seek to escape from all liability, but. they ask that in justice the original utterer of the slander shall bo made, if not primarily, at least partially, responsible for it. What is sauce for the goose ia surely sauce for the gander. “There ia an immense difference,” rightly says the author from whom I am quoting, “between holding a person not" entirely blameless and making him alone blameworthy.” The true remedy for this intolerable position in which the press find themselves was pointed out by Mr 1 W. Flux, a solicitor who, giving evidence before the House of Commons! Committee, said: —l think that-, probably, the most expedient thing would be to provide that in all cases where newspaper proprietors are proceeded against in respect to slander (uttered at these meetings, the speaker of the slander shall be joined in the action, either originally or under the. modern procedure, which allows a person entitled to an indemnity to join the in-. demnified in the action, and that whilst the newspaper proprietor shall for his part remain responsible to the slandered person, he shall be entitled to a remedy overagainst the speaker unless there lias" been collusion between them, and that a fair report of spoken words shall not be liable, but shall remain as spoken, that is, as slander.
It has been pointed out by those competent to give an opinion on the legal aspect that there is no necessity under the circumstances given above to treat, the speech complained of as slanderous; it should be treated for what it actually is—libellous, hut the original speaker of the libel should only be held answerable for his utterances when he was awaxo of the presence of reporters for taking, the speeches to be made; and that the jury who try the cause should be empowered to assess the measure of damage between the utterer of libel and the publisher of it, when giving a verdict for plaintiff.
A third and equally grievous injustice suffered by the press is the liability we are all under to be shot at by the unscrupulous litigant, too often aided by the unscrupulous lawyer. Hence the demand all over the Empire for giving to the Judges, in specific power to compel plaintiffs to deposit reasonable security for costs, and for th© consolidation of actions where simultaneously brought in respect to one libel. In every part of England the operation of the existing law lias been shown to be in a very different state to what wag intended by Parliament, but the agitators (again, in a different sense from what Mr Fisher conveyed to the House) have not. yet suoceeded in inducing tho present Lord Chancellor of .England (Halsbury) to admit the reasonableness of a proposition that will eat . into the profits of the profession whose interests’ are, and have always been, so carefully guarded by that great legal luminary?. The need for such a provision every journalist and every proprietor in the colony can testify. During my thirty years’ connection with tho journal I represent I am not cognisant of having been called on to defend more than half a dozen libel suits, only one of which went against U 3. "We won all the others, but in defending all save one we had to pay not only our own costs, but failed to recover our costs from 3ie plaintiff, who in each instance but one was a man of straw. This clause in Mr C'arncross’s Bill ought to pass. There are a couple cr clauses in,Mr Fisher’s Bill that I do not offer any objection to, but in saying this I am speaking wholly for myself, let it be understood. Any paper publishing libellous matter ought to afford the aggrieved party the earliest opportunity of putting himself right before liis fellowcitizens, but it should bo left to the jury to say whether the paper lias refused to afford him “reasonable” satisfaction. In my experience I have met men who would not be content with any “ reasonable ” amount of space; they, wanted a “ leader ” to in addition to several inches of “leaded” type. But in the great majority of cases I opine that editors will experience in the future, as they have always dono in the past, little, difficulty hi meeting men who approach them main amicable spirit. No respectable newspaper will dissent from Mi- Fisher’s proposition to severoly punish the journal that publishes reports of proceedings in camera against the express direction of the Courts; and no penalty can be too severe, say I, in such cases: We don’t want a gutter press established in" this •colony. To clause 5 (compelling a pro-
priotor to disclose the name of a correspondent who may write a there will be strong opposition, bccauoe it strikes at the anonymity of the press. Editors and proprietors have either to give up the names of correspondents who attack a man unjustly, or take the consequences of shielding him. That is a Well-established canon of press ethics, and will never be abandoned, though I, for my own part (and always with the approval of my proprietors) have immediately surrendered the name when it have had reason to believe that the borrespondont deceived mo by alleging to be facts statements which proved to be the reverse of facts. And that course I shall always follow, though it may subject me to the imputation of breaking through a well-recognised rule. I have said already that to my thinking, the principal clause of Mr Carncross’s Bill will not give to the press that measure of relief and contentment that we all know' the member for Taieri is anxious to confer on the craft to which he belongs. Infinitely preferable in mv opinion—an opinion that is shared, I am aware, by many proprietors and journalists -with whom 1 have conferred on the subject '—is the crucial clause (13) of the Queensland and Tasmanian Acts, which found their W'ay into Sir P. Buckley's Bill of 1893. 13. It is lawful—
(1) To publish in good fait'-, for the information of the public, a fair report of the proceedings of either House of Parliament, or of any committee thereof; „ (2) To publish in good faith, for the information of the public, a copy of, or an extract from or abstract ot, any paper published by order or under the authority of either House of Parliament; (3) To publish in good faith, for tho information of the public, a fair report of the public proceedings of any Court of Justice, -whether such proceedings are preliminary or interlocutory or final, or of the result of any such proceedings, unless in the case of proceedings which are not final, the publication has been prohibited by the Court, or unless the matter published is blasphemous or obscene; (4) To publish in good faith, for the information of the public, a fair report of tho proceedings of any inquiry held under the authority of any statute, or under the authority of her Majesty, or of the Governor-in-Council, or an extract from .or abstract of any such proceedings, or a copy of or an extract from or abstract of any official report xnado by the person by whom the inquiry was held; (5) To publish in good faith, for the information of the public, at the request of any Government office or department, officer of State, or officer of police, any notice or report issued by such office, department or officer for the information of the public; (6) To publish in good faith, for tho information of the public, a fair report of the proceedings of any local authority, board, or body of trustees or other persons, held or purporting to be held under the provisions of any statute for the discharge of public functions, so far as the matter published relates to matters of public concern; (7) To publish in good faith, for the information of the public, a fair report of the proceedings of any public meeting, so far as the matter published relates to matters of public concern. The term “public meeting” means a meeting lawfully held for a lawful purpose, and for the bona fide furtherance or discussion of a matter of public concern, or for the advocacy of the candidature of any person for a public office, whether tho admission to the meeting was general or restricted. The question whether a meeting is a public meeting is a question of law. f A publication is said to be made in good faith, for the information of the public, if the person by whom it is made is not actuated in making it by ill-will to the person defamed, or by any other improper motive, and if the •manner of the publication is such as is (Ordinarily and fairly used in the ease Of the publication of news or information.
In the case of a publication of a report of the proceedings of a public meeting in a periodical, it is evidence of a want of good faith if the proprietor, publisher or editor has been requested by the person defamed to publish in the periodical a reasonable letter or statement by way of contradiction or explanation of the defamatory matter, and has refused or neglected to publish the same.
The Queensland law has been in operation over twelve years, so that there has been ample time in which to test its merits, and to discover whether its enlargement of protection to tho press of that colony lias been followed by
any misohievous results. On these pou ts hear the testimony of the preJustice (Sir Samuel Griffith), a jurist of acknowledged preeminence, In a letter, addressed two ye«ts ago to the present Acting-Pre-mier, he wrote:—
Dear Mr Ward, —You are perhaps asking a prejudiced Judge as to the Queensland defamation law. It was passed in 1889, and is now (except two or throe clauses relating only to civil actions) re-enacted in the Criminal Code passed last session, with only one or two verbal emendations. Sinco it was passed there have been singularly few actions for defamation. The law is so clear and simple that everyone can tell what he may or may not do, and the duty of a Judge at the trial is very plain and simple, all the necessary‘directions to the jury being, in effect, contained in the statute. As I said. I may be prejudiced, but I am very proud of my handiwork, and do not know of any exceptions having ever been taken to any of its provisions. It has. as no doubt you aro aware, been adopted in Tasmania. : —S. W. GRIFFITH.
I took it on myself to inquire from Mr L. E. Groom. M.H.R. (one of the Queensland members of the Federal. Government, who is a prominent member of tho Queensland Bar, and has acted as a Supreme Court Judge), what had been his experience of the working of Sir S. W. Griffith’s Act, and his reply speaks for itself:—
The law in Queensland has been found in its operation to be beneficial both to the public and the press. The liberty of the press has been secured, while at the same time due provision is made for the recovery of damages by any person defamed through the improper publication of injurious statements or criticisms. I have bad professional experience in the working of tho statute, and can hoar testimony to its practical utility. By the statute (a copy of which has been forwarded to you herewith) you will see that the law of defamaation is really in the form of a code. The distinction between libel and slander, injury from words written and spoken, has been abolished. A general definition has been given (section 4), and by this is tested each newspaper article upon which legal advice is sought. It is by this test that the jury decide whether matter is defamatory or not (section 5). Matter may bo defamatory, yet its publication may.be excused or justified by law (section 8). It is quite lawful to publish defamatory matter with respect to reports of matters of public interest. This protection covers all proceedings of Parliament, Parliamentary papers, proceedings of Courts of Justice, and official inquiries, public notifications by tho Government, proceedings of local authorities and public meetings—provided, of course, that all these are published in good faith. Papers, however, are more wont to be subject to actions for comments published. In Queensland, “fair comment” is a statutory defence. It is allowed with respect to public proceedings, the public conduct of public men, public conduct of public officers, proceedings in Courts of Justice, hooks, public exhibitions or performances, public entertainments, and all matters communicated to the public. It is for the jury to. determine whether tho comment is fair. Truth is an allowable plea, but to succeed the matter must he proved to be true and for the public good. Provision is made for the innocent sellers of periodicals containing defamatory .matter, and a measure of protection is given to the proprietor in whose paper defamatory matter is published without his knowledge, and with no neglect on his part (sections 22 and 33). The sections dealing with evidence (38 and 39'' have been helpful in practice to plaintiffs. Section 43 has been found an excellent deterrent in making the proprietor of the machines and type responsible for the articles printed by his material. I have in the above given you onlv. a brief reference to the leading sections. I feel sure that yeu might, with advantage, adopt its principles in New Zealand. Hoping that this hurried and discursive note may be helpful to you.—l am, etc.,
LYTTELTON E. GROOM
P.S.—ln respect to your question, I can say that the present statute has not led to any “abuse of their present privileges” by the press of Queensland. Their position is clear and defined, and any “abuse of privilege” would he an infringement of the law.— L.E.G.
In the face of such testimony, which ought to carry conviction to the mind of every impartial person, it is idle to question the efficacy of such a law, based’ as it is on the broadest principles of justice and freedom. Recognising how futile it is for any private member., no matter at what period of the session, to overcome opposition proceeding from the quarter I indicated in the early part of this letter—opposition that is not amenable to reason, but is founded on personal antipathy and vindictiveness—l appeal to the Government of the country to take up this question as one affecting the wellbeing of an institution that is second to none among the forces that make for national greatness. I say it without fear of contradiction, and I can claim to have had opportunities for instituting tho comparison equal to those given to most men, that the press of New Zealand is on the whole as morally clean, free from corrupt influences, and
ably conducted, as the press' of any other part of the British Empire, not excepting the heart of the Empire itself. I take leave to say, knowing them as intimately as I do, that the men who control the destinies and fortunes of our principal newspapers are actuated solely hv a desire to elevate the communities in which they work and live, and to assist by every means in their power to further the material, moral and political advancement of this fair country. Mistakes of the head wo may make, but of the heart never. In the heat of political warfare we may smite at our opponents at times with an amount of bitterness that the circumstances, looked on calmly after the smoke of battle has faded away, did not possibly warrant, and which we are often sorry for, but our accusers have it not in their heart of hearts to charge us with what the law terms “malice aforethought.”. Even the late Sir John McKenzie, than whom, at one period of his eventful and stirring life, there was no more pronounced enemy of the press and nearly all connected with it, frankly acknowledged, with his almost dying brea-th, that he had misjudged our institution and unwittingly done injustice to a class of colonists whose impress on the work of colonisation can never he effaced. If the late Minister of Lands, conscious of his own infirmities, cohld make such an acknowledgment (of which I am not the only surviving auditor) in terms so handsome thaat they have left in the hearts of the pressmen only a feeling of veneration for his memory and (admiration for his great. work, surely I can ask other public men whose displeasure we appear to have incurred to rise above personal con-
siderations, and to join hands with those who wish to put the press of this colony in a position, not of superiority to, hut of equality with the press of the most progressive of our sister colonies, as well as with the press of tlio Homeland, with which we are affiliated.
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New Zealand Mail, 17 September 1902, Page 69 (Supplement)
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5,754THE LAW OF LIBEL New Zealand Mail, 17 September 1902, Page 69 (Supplement)
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