The Gee case: the BBC settles.

"intended to be read in the privacy of the chamber by married women or by those contemplating marriage, and is not intended for the publicity of the streets, or to satisfy the curiosity of the vicious." It was sold by non-professional booksellers for sixpence.) Qualified privilege may take many forms. Probably the most important form is the wide class said by the judges to be made pursuant to a common and corresponding duty and interest. The example most commonly given is that of an employer giving a reference for a former employee. The former employer gives a reference as a matter of duty and publishes it to a prospective employer who has a common and corresponding interest in receiving it. In medical terms probably the most common example is that of the general practitioner writing a letter to a consultant or the consultant replying. Such letters would clearly be protected by qualified privilege, though a jury might well find that some of the more unnecessary comments on the patient's character were outside the protection of the privilege. Entries in a patient's notes in a hospital or in a general practitioner's NHS practice are bound to be published to someone other than the writer at some time, and that occasion of publication might be complained of in a libel action. The publication would be protected by qualified privilege if, but only if, the publication is to someone deemed by the trial judge to be within the ambit of the duty/interest relationship. That protection would be lost on proof by the plaintiff that the doctor was actuated by malice when he wrote the words. What is malice? The only short answer to that question is that the determination of the issue of malice may cost a lot of money.