D published a book that claimed D had been a corrupt police officer. Qualified privilege failed since the “duty” element (i.e. journalistic standards) had not been fulfilled. The burden of proving journalistic standards had been upheld was on D. CA reasserted the interest-duty test. The factors set out in Reynolds for determining this were indicators, not hurdles/formal requirements, and weight should be given to the journalists professional judgment. Reynolds should be viewed as striking a balance between articles 8 and 10 ECHR, coming down more on the side of free speech.