Is there any case law in which a publisher is held responsible for the repetition of a libel by a third party?

It is uncontroversial that every republication of a libel is a new libel and each publisher is responsible for his act. If this were not the case, the original publisher would become responsible for the acts of those over whom it has no control. In the very old case of Speight v. Gosnay (1891), 60 L.J.Q.B. 231, a case involving slander, the court identified exceptions to this rule. The one in question here is whether the repetition is the natural and probable consequence of the original publication.

In Cohl v. Donovan, [1996] O.J. No. 3857, per O’Driscoll J., the plaintiffs pleaded the fact of republication as follows: The impugned paragraphs of the Statement of Claim state: 48. Further, the publicity generated by the publications at issue has resulted in the widespread republication of the false and defamatory statements in the print and electronic media. The republication of the statements was a natural and probable consequence of the publications. The defendants are therefore liable for the further damage caused by the republication. 49. As a result of the republication of the allegations, the plaintiffs have suffered further substantial damage.