How have courts interpreted the rule of privilege in the context of a libel action brought by a party who has been scandalized in a libel case?

the person scandalized, and who complained, was not a party to the cause. Henderson v. Broomhead, 4 Hurl. & N. 569. There is no good reason for limiting or weakening the rule of privilege applicable to publications made by one to another in regard to matters of business in which both are interested. Whenever such occasions are used as a cover to gratify personal spite, by intentionally or wantonly assailing personal reputation, ample redress can always be given to the injured party upon proof that the publication was actually inspired by malicious motives; and this is sufficient for every purpose of justice. The general term was correct in holding that the matter was privileged, and its judgment should be affirmed.