KIIT SCHOOL OF LAW

MEANING & SCOPE OF INNUENDO: CASE-LAW DEVELOPMENT IN UK AND INDIA

LAW OF TORTS

Submitted by:

Jigme Singye Roll No. 1183023 Second Semester B.A.,LL.B (Hons)

Submitted on: 4/04/2012

Acknowledgement
I would like to take this opportunity to express my gratitude to the Faculty of Law of KiiT, specially our subject teacher Ms. Divya Salim. And this project wouldnt have been a successful one without my co-partner Mr. Kingshuk Halder, who has been an utmost help in the completion of this piece. Lastly, I would like to thank the entire library staff for providing us with the various sources of information that I have utilized during the course of my project.

Table of Content
s.no 1 2 3 4 5 6 7 8 9 10 11 Chapter Acknowledgement List of Abbreviations Introduction Defamation Libel and Slander Innuendo Defenses to Innuendo Remedies for Innuendo Case Analysis Conclusion Bibliography Page 2 4 5 6 8 10 13 16 17 20 21

List of Abbreviation
1. AA ER- All England Reporter 2. EMLR- Entertainment and Media Law Reports 3. QB- Queens Bench 4. V-versus

INTRODUCTION
Innuendo is a Latin word which means an explanatory averment in the statement of claim defining the meaning which the plaintiff assigns to the words complained of or specifying the plaintiff as the person to whom they apply. Innuendo is a topic which is studied under the torts of defamation. So it is imperative on our part to know about defamation. What defamation is and what are its various types. Defamation: Every man has the right to have his reputation preserved in inviolate. This right of reputation is acknowledged as an inherent personal right of every person as part of the right of personal security1. The law recognizes defamation as a jus in rem, a right good against the entire world. So there, we can estimate that reputation enjoys an utmost essential place in an individual life and that, nothing should be done to harm the reputation of an individual. The concept of defamation finds place in Torts. The main point of Defamation is what other people think about an individual since reputation is what other people think and not an individual thinking of himself. The existing law relating to defamation is a reasonable restriction on the fundamental right of freedom of speech and expression conferred by article 19(1) (a) of the Indian Constitution and is saved by Clause (2) of Article 19. The case of defamation becomes complicated because words used, more often than not, have more than one meaning. Thus, the interpretation of sentences spoken or written lies to the discretion of the person who hears or reads them. However, the interpretation cannot be random and arbitrary; it must conform to reasonability of a common man. Interpretation of sentences is thus, very important in the tort of defamation and because of this there exists a highly specialized branch of innuendo within the tort of defamation. Innuendos refer to those sentences which although seem to be innocent prima facie but have a latent meaning, which is defamatory in nature. A false or popular innuendo is where the words bear a meaning that is not their literal meaning but instead constitutes an inference or implication from the words themselves. The question is whether a reasonable reader might read between the lines. In such cases, the natural and ordinary meaning of the words is not their literal but their inferential meaning.

Blackstone Commentary of the Laws of England, vol.i(4edt) p 101

DEFAMATION
A defamatory statement is a statement calculated to expose a person to hatred, contempt or ridicule, or to injure him in his trade, business, profession, calling or office, or to cause him to be shunned or avoided in society.2 This is known as publication of the statement, which in its true legal sense means the communication of defamatory matter to some person other than the person of whom it is written. Defamation, under Indian Penal Code, means the wrong done by a person to anothers reputation by words, signs, or visible representations.3 Defamation also differs from insult caused by words or representations. The former is a wrong done to the regard or esteem in which one is held by others while the latter is an injury of selfrespect. Therefore the former requires publication to a third party while insult may consist in abusing a person only in his hearing. While the former is an actionable wrong, mere insult is not actionable, though where it accompanies wrongs like defamation, assault or trespass; it will be considered as an aggravating circumstance and will enhance the damage. 4 The essence of defamation is to anticipate a term publication, whereas Insult per se constitutes no civil wrong. Nevertheless, the law will take into consideration only the opinion of right-thinking members of the society and not of the uncultured people like criminals. In Mawe v. Piggot5, an Irish priest sued for words charging him with being an informer against a certain class of Irish criminals. He argued that amongst certain classes who were either themselves criminals, or who sympathized with crime, it would expose a person to great odium to represent him as an informer or otherwise acting in the detection of the crime. However, it was held that though he was injured in the sight of the criminal community, being an informant actually raised him character in the estimation of society at large as this was a heroic thing. Hence, the defendant did not commit the tort of defamation.6 In a civil action for defamation, intention of the defendant is, in general, immaterial. Defendants published in a newspaper the photograph of plaintiffs husband with that of a Miss X, announcing that they were engaged. The photograph as well as the caption was supplied
2 3 4 5 6

R. Ranchhoddas et al.,,Law Of Torts 196 (India: Wadha and Company Pvt. Ltd.,1987). Section 499, IPC R. Iyer, The Law Of Torts 334 (India: Lexis Nexis Butterworths, 2003). 1869 Ir Rep 4 CL 54. P.SA. Pillai. Law of Tort 41 (India: Eastern Book Company, 2004).

by the plaintiffs husband and the respondents had no reason to oppose that the plaintiff was not single. Held that though defendants had no reason to defame the plaintiff, plaintiff was entitled to damages since the publication was capable of bearing the meaning that the plaintiff was the mistress of her husband. [Cassidy v. Daily Mirror (1920) 2 KB 331] Defamation is in some cases also a criminal offence. In India, while the criminal law of damages is codified in Sec. 499 of the IPC, the civil law of defamation is not yet codified and still rests on English Common Law.7 And Defamation will not apply to a class of persons, only an individual can bring an action if he can show that it applies to himself. If a man wrote that all lawyers were thieves, no particular lawyer could sue him unless there is something to point to the particular individual. The precedents for group defamation were laid out in E.E.J.P.U. v. London Express Newspaper Ltd8, where it was held that a group must have legal entity in order to be defamed.

The requisites of Defamation:

1. The statement must be defamatory; 2. The statement must refer to the plaintiff; 3. The statement must be published; 4. The essence of malice must be demonstrated.

Curiously in England, the law of Defamation has now been codified and reformed in the Defamation Act, 1952. The law applicable in India is the common law which existed prior to this Act and apart from the statutory changes. 8 (1980) QB 585

LIBEL AND SLANDER

The word defamation is the generic name for the wrong: libel and slander, which are particular forms of it. The question whether a statement or representation falls within one or the other category is important in USA and England where a slander unlike libel is not always actionable or punishable. It is not material in India where both are treated alike.

Slander
A Slander is a false and defamatory statement by spoken words gestures tending to injure the reputation of another. The spoken damage must appear to be the natural consequence of the words spoken. Example includes the loss of a customer, or the loss, refusal of some appointment or employment, or the loss, refusal, the loss of the consortium of ones husband.

Exceptional cases of Slander actionable per se: There are four exceptional cases in which slander is actionable without proof of special damage. 1. Imputation of a criminal offence punishable with imprisonment: There must be a direct imputation of the offence, not merely of suspicion of it and the offence must be punishable by imprisonment in the first instance. 2. Imputation of disease: An imputation of a contagious or infectious disease likely to prevent people from associating with the claimant is actionable per se. There is an ambiguity about the scope of this. It has always included venereal disease and plague and leprosy. It does not arise from the likelihood of moral censure for long ago. An obvious issue today whether it covers AIDS. The law is so obscure that it is submitted that either the category should be extended to every serious communicable disease. 3. Imputation of unchastely to a female: At common law an imputation of unchastely to either sex required special damage, but the slander of Woman Act 1891 made it actionable per se to impute unchastely9 or adultery to any woman or girl.

Held in Kerr v Kennedy (1942) 1 K.B 409

4. Imputation of unfitness or incompetence: This is by far the most imperative exception because the most frequently invoked. It is actionable per se to impute to any person unfitness, dishonesty or incompetence in any office, profession, calling trade or business carried on by him at the time when the slander was published. Though there is no decisive authority calculated to probably mean likely to. What will satisfy this test is of course going to turn on the nature of the office and the nature of the charge: a charge of uncharitable behavior against a clergyman may be more likely to be damaging than the same charge against an ordinary person. These are some of the exceptional cases of slander actionable per se. in other words if defamatory word is used against these headings it will be actionable in the very first instance.

Libel
A libel is defamation in some permanent form. Example: written or printed defamation. At common law, a libel is a criminal offence as well as a civil wrong. A libel is a publication of a false and defamatory statement tending to injure the reputation of another person without lawful justification or excuse. The statement must be expressed in some permanent form e.g. writing, printing, pictures, statue, waxwork effigy etc.10 There are three main components of libel. Any action to come under the preview of libel must satisfy these three components and they are: 1) The statement must be false 2) It has to be in some permanent form (such as in writing) 3) The statement must be defamatory. The statement must be false: The burden of proof that the words are false does not lie upon the plaintiff. Defamation of a person is taken to be false until it is proved to be true. Further if a man has stated which is false and defamatory, malice is also assumed. The motive of the defendant is not material in determining the liability of libel. It has to be in some permanent form, in writing: Being in a permanent form, it supports the view that the distribution of the record by the manufacturer like the distribution of any printed matter is libel and the speaker whose will be
10

The Law of Torts. Ratanlal & Dhirajla (25ed) Wadhwa and Company Nagpur p264

vicariously liable for libel along with the manufacture and the distributor. Under the Defamation Act, 1952 the broadcasting of words by means of wireless telegraphy i.e. radio and television is treated as publication in permanent form. It has to be defamatory: Any words will be defamatory which Expose the plaintiff to hatred, contempt, ridicule, or obloquy Tend to injure him in his profession or trade Cause him to be shunned or avoided by his neighbors.

These are certain features of libel or the components of libel, and for the statement to constitute libel all these components need to be fulfilled. In India, the rule of the English law in regard to slander is not observed. Both libel and slander are criminal offences under the Indian Penal Code, Section 499 and also actionable without proof or special damage.

INNUENDO
This is the topic in which we are really interested in. Till now, we were having the background of our project, but now we come to our real project. We will be analyzing the definitions of innuendo, then proceeding on with the case analysis and with analysis we will be concluding our project. Innuendo (from innuo, which means to nod or beckon with the head) is a word used in declarations and law pleadings, to ascertain a person or thing which was named before. As per Advance Law Lexicon, Innuendo is an oblique remark or indirect suggestion, usually of a derogatory nature. In criminal law, an innuendo takes the form of a statement in an indictment showing the application or meaning of matter previously expressed, the meaning of which would not otherwise be clear. In the law of defamation, an innuendo is the plaintiffs explanation of a statements defamatory meaning when that meaning is not apparent from the statements face. An innuendo is an explanation of the meaning of the words published or spoken by a reference to facts previously ascertained by averment or otherwise. The purpose of an innuendo is to define the defamatory meaning which the plaintiff attaches to the words and to show how they came to have that meaning and how they relate to the plaintiff.

The word innuendo is applied to signify, in a proceeding for the defamation, the averment of a particular meaning in a passage prima facie innocent, which if proved, would establish its defamatory character. If a statement does not convey any defamatory imputation in its natural sense, it may be because the words are innocent or true or have two or more meanings some of which are innocent, or have no well-known meaning as in the case of slang, provincialisms, local or technical term not in common use. In all such cases the plaintiff should set forth, by a statement in the plaint known as innuendo, the special or secondary meaning of a defamatory character, which the words complained of conveyed to the persons to whom they were published.

The responsibility of Innuendo is merely to interpret the meaning of the language used. The natural and ordinary meaning includes implications: it is as defamatory of A to say that justice miscarried when he was acquitted of murdering X, as it is to say outright that he did murder X. Juxtaposition of material about the claimant with other material may make an otherwise innocent statement defamatory. The most famous instance of innuendo is Monson v. Tussauds Ltd. The defendant, who kept a waxwork exhibition, placed an effigy of the claimant, with a gun, in a room adjoining the Chambers of Horrors. The claimant had been tried for murder in Scotland and released on a verdict of Not Proven and the representation of the scene of the alleged murder was displayed in the Chamber of Horrors. The court of appeal considered that although in all the circumstances the case was not suitable for the issue of an interlocutory injunction, the exhibition was capable of being found by a jury to be defamatory. There we can see that how the concept of innuendo came into picture, in other words we come across the evolution of innuendo as defamation.

In the case of true innuendo:

It is not a true innuendo to repeat the obvious meaning of defamatory words in other language, or in an embroidered or exaggerated way. Otherwise an ingenious pleader could perplex the judge and jury and harass the defendant by ringing the changes on the same words, creating numerous different causes of same words, each requiring a separate verdict. A true innuendo relies on a conjunction of the words used and some extrinsic fact. Thus it is defamatory in itself to say that a mans affairs are being investigated by the Fraud Squad: but the statement does not support the innuendo that those affairs are being carried on fraudulently. Conversely, the statement X is a

good advertiser is innocent in itself, but carries a libelous innuendo if published to persons who knew the innuendo if published to persons who knew the extrinsic fact that X is an eminent member of the Bar.11 In each innuendo there is a separate cause of action. The cause of action based on natural or ordinary meaning is materially different from the cause of action based on special meaning derived from special circumstances. There may arrive a condition when there may be a difference in the meanings of the words used, but to establish the true and contextual meaning of the word used, it will be the duty of the plaintiff or the complaint as the case may be so. It has already been said that there is no rule that, before an article could be said to be defamatory of a person, it must contain within itself key or pointer indicating that it is referred to him.12

When the plaintiff relies on the natural and ordinary meaning without reference to any special circumstances and pleads the meaning according to him is the natural meaning, such plea is popularly called as pleading an innuendo. But this is very much different from the cause of action since cause of action takes into various other facts into consideration.

11 12

R.F.V. Heuston. Salmond on the Law of Torts. (1th edition) 149 The Law of Torts Ranchhoddas Ratanlal & Thakore Keshavlal Dhirallal (edn 25) Wadhwa and Company, Nagpur p.272

DEFENSES TO INNUENDO
General defenses which are applicable tall torts also apply to defamation and innuendo. Specific defenses to defamation reflect the importance of defamation law accords to freedom of speech.13 These include: 1. Justification 2. Privilege 3. Fair and bona fide Comment

JustificationThis is the plea of the truth of the words published by the defendant. If he can prove it, he has a complete defense even if the statement was made maliciously. The underlying principle is that the law will not permit a man to recover damages in respect of an injury to a character which he does not possess. The law does not enjoy incessant infliction of the truth on people, but an injury a persons reputation must be castigated. If others think the worse of him on hearing the truth, there is no injury to his reputation as it has been restored to its proper level. Truth, though, is not a defense unless its publication is in public interest but if the defendant decides to make use of justification as a defense, he must exercise caution in doing so, for if he fails, the jury might aggravate the damages as punishment for trying to mislead the jury. Showing that he reproduced accurately to a third party what he had heard from another is not a valid defense. If the words imply the commission of a specific offense, it is not enough that the claimant was suspected of the same. Such restrictions on the use of this defense are necessary to prevent arbitrary use and/or abuse. Only false statements are actionable, so if the statement made about the claimant is true, there can be no action for defamation. The burden of proof is on the defendant, which is to prove that the statement made is true. If a number of imputations are made by the defendant but only one action is brought by the claimant in respect of them, then by virtue of Defamation Act 1952, a defense of justification shall not fail by reason only that the truth of every charge is not proved if the words not proved to be true do not materially injure the claimants reputation, having regard to the truth of the remaining charges.
13

Street, Torts, 501 (John Murphy ed., 11 edn,. London: LexisNexis. 2003)

th

PrivilegeThe law recognizes that occasions on which free communication without fear of an action for defamation are sometimes more important than a persons right to unblemished reputation. Such situations are called privileged and the privilege may be either absolute or qualified. According to Salmond, A privileged statement may be defined as one which is made in such circumstances as to be exempt from the rule that a man attacks the reputation of another at his own risk.14 Privilege normally exists in cases where a valid reason for publishing defamatory matter in public interest or to shield the rights of individuals. When the allegation is false, or cannot prove to be true, it is necessary to prove that the defendants privileged position exempts him from facing the consequences of his error. a) Absolute privilege: There are certain occasions on which the law regards freedom of speech as essential, and provides a defense of absolute privilege which can never be defeated, no matter how false or malicious the statements may be. The following communications are absolutely privileged and protected from defamation proceedings. Statements made in either House of Parliament Parliamentary papers of an official nature, i.e., papers, reports and proceedings which Parliament orders to be published. Extracts from parliamentary papers are covered by qualified privilege. Statements made in the course of judicial proceedings or quasi-judicial proceedings. Fair, accurate and contemporaneous reports of public judicial proceedings before any court. Communications between lawyers and their clients. Statements made by officers of state to one another in the course of their official duty.

b) Qualified privilege Unlike the defense of absolute privilege, in this case it is necessary that the statement must have been made without malice. Also, there must be an occasion for making the statement. His privilege is generally available either when the statement is made in discharge of a duty or protection of an

14

Heuston et al, Salmond ad Heuston on Torts. 150, (18 edn.. Sweet & Maxwell, 1981).

th

interest or the publication is in the form of report of parliamentary, judicial or other public proceedings. Thus, to avail this defense, the defendant has to prove the following: The statement was made on a privileged occasion i.e. it was in discharge f duty or protection of an interest The statement was made without malice.

Fair and bona fide commentThe defense of fair comment is frequently relied upon by the press, as it is designed to protect statements of opinion on matters of public concern. The defense only applies to comments made on matters of public interest, e.g. comments on works of literature, music, art, plays, radio and television; and also the activities of public figures. A publication made maliciously (spitefully, or with ill-will or recklessness as to whether it was true or false) will destroy the defense of fair comment. Where there are imputations partly based on fact and partly expressions of opinion, the defense of fair comment will not fail merely because the truth of every allegation of fact is not proved if the expression of opinion is fair comment having regard to such of the facts alleged or referred to in the words complained of as are proved.

REMEDIES FOR INNUENDO

The usual remedy for innuendo is a civil action for damages. The plaintiff can ask for life by way of an injunction to prevent a threatened publication of defamatory statements. The remedy of criminal prosecution is also available, and frequently invoked in India. A suit for damages may also be brought. In a suit for damages for defamation the law requires that the plaintiff ought to allege the publication of defamatory statement, set out the actual words used and also state that they were published or spoken to the same named individuals and specif the time and place when and where they were published. Damages: Damages are awarded in one lump sum, but fall under two different heads(i) General damages by way of pecuniary reparation15 or solatium16 to the plaintiff for the annoyance, mental pain, inconvenience, etc. (ii) Compensation for the special damage that he has sustained as a direct consequence of the publication. Injunction: The Court has jurisdiction to interfere on an interlocutory application to restrain the publication of a libel. But this jurisdiction will not in general be exercised unless the applicant satisfies the Court that the statements in the document complained of are untrue. Further there should be some likelihood of immediate and pressing injury to person or property of the plaintiff or his trade.

15

The making of amends for a wrong one has done, by paying money to or otherwise helping those who have been wronged 16 A thing given to someone as a compensation or consolation

CASE ANALYSIS
SLIM v. DAILY TELEGRAPH LTD., (1968) 1 All ER 497
Material Facts The plaintiff, S, became legal advisor to V. Ltd., who had a factory in Hammersmith. Some years earlier the Hammersmith Council had put up a notice signed by S. as town clerk forbidding cycling along it. Later S. as legal adviser of V. Ltd. had a right of way for vehicles over it. The defendant newspaper published a letter from H., a local resident, entitled 0Double Think, referring, inter alia, to the removal of the notice signed by S., which, the letter said, might have made local residents a little cynical and stating that it was Plaintiff who on behalf of the firm to which he was legal advisor claimed the right to drive lorries along the path. Later the newspaper published a letter from G., the chairman of V. Ltd., disclaiming any intention by his company to use the way for lorries. Further, the newspaper published a further letter from H. saying, inter alia, that the intentions of V. Ltd. were obviously to establish the vehicular right of way willy-nilly, without even waiting for a decision from the council. S., V. Ltd. and G. brought a libel action against the newspaper and H.

Judgment of the Court of Appeal All three plaintiffs were awarded substantial damages.

Reason That the letter bore the imputation that S. had brought improper pressure to bear on the council employees and was not fit to remain a solicitor and that the letter bore the imputation that G. and through him V Ltd. was insincere and hypocritical and had been guilty of improper conduct.

Ratio Whether the text of a newspaper article will, in any particular case, be sufficient to neutralize the defamatory implication of a prominent headline will sometimes be a nicely balanced question for

the jury to decide and will depend not only on the nature of the libel which the headline conveys and the language of the text which is relied on to neutralize it but also on the manner in which the whole of the relevant material is set out and presented.

BRENT WALKER GROUP PLC v TIME OUT LTD, (1991) 2 QB 33

Material Facts Time Out and one f its journalists were sued for libel in two articles reflecting adversely on the conduct of first plaintiff and its chairman, the second plaintiff. The defendants pleaded fair comment relying, among other things, on statements allegedly made by prosecution witnesses in a criminal trial at which the chairman had been convicted of theft, and at other trials involving alleged associates of the chairman. The plaintiffs applied to strike out these parts of the defense on the grounds that the statements in question had not been included or referred to in the articles complained of, nor did the defendants allege that they were true, they could not therefore form a legitimate part of a fair comment defense.

Question before the Court Was it a requirement of the established defense of fair comment on a privileged statement that t statement should have been made by the defendant, and included in the publication complained of?

Judgment of the Court of Appeal The paragraphs complained of were struck out.

Reason The privilege for what is said in Court is that of the witness; it does not extend to those who report what is said; they have privilege only for fair and accurate reports of proceedings.

Ratio The law requires a defendant relying on the defense of fair comment to show that his comment was based on a true account of the facts or a report which is privileged, because it is fair and accurate

and defense of fair comment on privileged material is an exception to the general rule that comment must be on true facts; policy does not justify widening the scope of the exception.

BEST v CHARTER MEDICAL OF ENGLAND LTD, (2002) EMLR 335

Material Facts The Claimant brought slander proceedings claiming that on nine occasions he had been the subject of defamatory remarks by the Defendant. The Claimant could not set out precisely what had been said, as he had not been present, but he could plead the gist of what had been said from what he had learned subsequently. The Defendant applied to strike out the claim o the ground that without specifying the precise words used, the Claimants claim did not disclose a proper cause of action. The Claimant contended that it was sufficient to plead the nature of the defamatory remarks and to proceed to seek further information about the precise words from the Defendant.

Question before the Court What degree of precision was needed in relation to the setting out of the words complained of in order to disclose a cause of action in slander?

Judgment of the Court of Appeal The suit was struck down and the defendant was held not guilty.

Reason The Claimant must set out the words alleged to have been spoken in the Particulars of Claim with reasonable certainty. It was not sufficient to plead that the Defendant had made a statement to the effect of some defamatory meaning.

Ratio It lays down the need for precision in the pleading of slander claims and that the circumstances in which a Claimant will be excused, a lack of precision will be rare indeed.

CONCLUSION
A just in rem (right against the whole world), is an inalienable and requisite part of everybodys property. The law of defamation exists in cognizance of the every individuals right to an impeccable reputation and the main responsibility of Law is to strike a balance between the interests of the injured and the speakers freedom of speech and expression and though there is a constant struggle between them, law takes note of this fact with great dignity and respect. For this reason, defamation law, like most other fields of law, is highly responsive to change depending on the facts of the case, the societys response to it, the injury rendered to the complainant, and the effect of the statement on the defendant even. The judge, chiefly, is required to arrive at a just and fair verdict while trying to appease all the parties involved in spite of taking all the above variables into consideration. Primarily, it is our utmost understanding that the defamation law is, and must, always be in a state of flux if human development is to take place (dynamic) and imperative on our part to let it continue to evolve. As it is on our very understanding that the demands of modern life are in many forms, it makes humans unable to arrive at an absolute conclusions about people and their reputations. And thus, defamation law takes even more precedence if we are to survive in cohesion. Innuendo is one of those portions of defamation which come under common law. As of today the consequences of innuendo are mild and the law ought to be made more stringent. The meaning of the word Innuendo has undergone a gradual change over time and the court has also widened its point of view when it decides the matters related to innuendo and defamation. Lastly, it is an essential part on us to note that sometimes the defenses available in defamation are not considered in innuendo.

Bibliography
Lists of Books
1. Street, Torts, (John Murphy ed, 11th edn., London: Lexus nexus, 2003) 2. Heuston et al, Salmond and Heuston on Torts, (18th edn., Sweet & Maxwell, 1981) 3. Ratanlal & Dhiraklal, The Law Of Torts (India: Lexis Nexis Butterworths, 2003) 4. Street, Torts, (John Murphy ed., 11th edn., London: Lexus Nexus, 2003) 5. Oxford Dictionary of Law

Websites
1. Country. "Innuendo in the Law of Defamation." Lawyers, Attorneys, Law Firms Find Legal
Information. N.p., n.d. Web. 24 Mar. 2012. <http://www.hg.org/articles/article_1790.html>.

2. "INNUENDO IN TORT - Forum - Law, Lawyers, Advocates, Law Firms,Legal Help, Legal
Experts,Judgements,Law Help, Indian Lawyers." Lawyersclubindia - Law, Lawyers, Advocates, Law Firms,Legal Help, Legal Experts,Judgements, Social Network for Lawyers, Legal Community, Law Help, Indian Lawyers. N.p., n.d. Web. 22 Mar. 2012. <http://www.lawyersclubindia.com/forum/INNUENDO-IN-TORT-2368.asp>.

3. "Torts Capsule Summary - Chapter 21." Business Solutions & Software for Legal, Education and
Government | LexisNexis. N.p., n.d. Web. 18 Mar. 2012. <http://www.lexisnexis.com/lawschool/study/outlines/html/torts/torts21.htm>.

4. "Westlaw India." Westlaw India. N.p., n.d. Web. 16 Mar. 2012.

<http://westlawindia.com/maf/wlin/app/tocectory?ao=o.I6FDFDCD04A2D11DF96C1A49DA6EE4E 28&ndd=2&sttype=stdtemplate&context=2>.