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Sharma v Singh & Associated Newspapers Ltd
Comment
There is a remarkable absence of recent authority on the application of the repetition rule where a level 1 meaning is sought to be justified. The decision affirms that the repetition rule applies with no less vigour to level 1 pleas of justification than to level 2 pleas (reasonable grounds to suspect). The decision is also notable for doubting the opinion expressed in Gatley that for conduct to qualify as harassment under the Act it must produce more than worry, trouble, discomfort or unease in the victim.