Watt v. Longsdon
King's Bench
[1930] I. K.B. 130
After receiving a letter from company manager Browne alleging that fellow employee Watt (plaintiff) had failed to pay debts and had an affair, director Longsdon (defendant) showed the letter to the company chairman, wrote back to Browne sharing his own negative views and requesting sworn verification, and then -- without ever receiving that verification -- separately showed the letter to Watt's wife, who subsequently separated from and divorced Watt. The trial judge found all the communications privileged and free of malice, ruling for Longsdon, and Watt appealed.
Whether an action lies for the malicious publication of a false, character-damaging statement unless the speaker had a duty to communicate believed-true information to someone with a material interest in it, an interest of his own to protect by communicating to someone believed to have a duty to protect that interest, or a common interest and reciprocal duty with the recipient regarding the subject matter.