In Keating v. Southam Inc. et al., (1999), 179 N.S.R. (2d) 208 Kennedy C.J. discussed innuendo and referred to it as being divided into two categories. False innuendo and true innuendo. He stated at page 212: ...False innuendo is a secondary meaning in which the words themselves are capable of bearing, and true innuendo is a secondary meaning which words can bear solely from the facts or circumstances not apparent on the face of the publication. If the plaintiff is alleging true innuendo, requiring knowledge of extrinsic facts on the part of the reader, to arrive at the alleged meaning beyond the words themselves, such extrinsic facts must be pleaded, or the claim cannot be understood. To the extent that the plaintiff claims defamation by innuendo, I agree the words creating the secondary meaning must be identified in the pleading. And further, if the innuendo is defamatory to the plaintiff, because of extrinsic fact or circumstances not mentioned in the article, then these must likewise be settled in the statement of claim to allow the defendants to know the case they must meet.
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