What is the test for a defamation claim against a newspaper?

The mere publication of defamatory words is presumed to be malicious. In this context, however, malicious, sometimes referred to as malice at law, merely means that the words were published without lawful excuse. For the plaintiff to rely on express malice there must be evidence to establish that the defendant had an improper motive for publishing the words and that the improper motive was the sole or dominant motive (Horrocks v. Lowe, [1975] A.C. 135).