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by gamblor956 4174 days ago
You've got that backwards. America <edit>and Canada are</edit> the only country in which truth is a defense to defamation.

Remember the British guy with the Nazi fetish? The tabloid that published that story lost even though it was true. In other countries (notoriously India), criticizing a government employee's performance is defamation (even if true).

Edit: Looks like Canada also allows for truth as a complete defense to defamation. That makes two nations out of 180+.

4 comments

Being a Kiwi, decided I better confirm what the story was here in New Zealand.

As with US and Canada 'truth' is a defence against defamation here also: http://www.medialawjournal.co.nz/?page_id=273

"The publisher will succeed with a defence of truth if it can prove, on the balance of probabilities, that the story was true. Minor errors may be excused, but not those that go to the heart of the defamatory sting or stings."

So guess you can add NZ to the list, but there are no doubt others - how about France, Australia, Austria.. Senegal?

Perhaps it is actually the UK that is the outlier in this regard?

I believe truth is also an allowed defence in Australia: http://www.thenewsmanual.net/Resources/medialaw_in_australia...
No it isn't. It is a defense in at least Canada as well.
> America is the only country in which truth is a defense to defamation.

Citation needed.