However with criminal libel publication to the person defamed is sufficient.
With Mr Galloway sitting in front of him, the judge said the MP had been seriously defamed.
defamed in this way.
The Deane the next day after, made an eloquent oration, wherein hee openly disgraced, and defamed hym.
Rich's suit claimed that Ashley defamed his character by going on a Florida radio show and publicly, falsely accusing him of striking Ashley, which Rich maintains he never did.