Malice is defined as “spite”, “ill-will”, or “any indirect motive or ulterior purpose that conflicts with the sense of duty or the mutual interest which the occasion created”. Malice may be established by showing that the defendant spoke dishonestly, or in wilful or reckless disregard for the truth: Hill v. Church of Scientology of Toronto, 1995 CanLII 59 (SCC),  2 S.C.R. 1130 at para. 145.
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