The defendant also refers to Netupsky v. Craig, 1972 CanLII 19 (SCC), [1973] S.C.R. 55, 28 D.L.R. (3d) 742. There, the court considered qualified privilege in the context of parties with a common interest and also where the defendant said he was replying to an unfair attack on his professional integrity and competence. Ritchie J. said at ¶8-9:
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