The leading authority on assessment of damages in libel actions is Hill v. Church of Scientology of Toronto, supra. Cory J.’s judgment affirmed that the following factors were to be taken into consideration by a judge or jury when assessing damages: 1) the plaintiff’s position and standing; 2) the nature of the libel; 3) the mode and extent of the publication; 4) the possible effects of the libel statement upon the life of the plaintiff; 5) the absence or refusal of any retraction or apology; and 6) the motivation and total conduct of the defendant throughout the action.
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