Report No. 33
35. Statements as to misconduct of public servant.-
Generally also, a statement as to the misconduct of a public servant made to the proper authority does enjoy qualified privilege.1-2-3
1. Gatley on Libel and Slander, (1960), p. 216, para. 374.
2. Jenoure v. D. Elmege, 1891 AC 73.
3. Jusab Morrsision, (1912) 15 Bom LR 249.
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