What is the current state of the law on permanent injunctions?

Courts have granted applications for a permanent injunction where it is likely that the defendant will continue to publish defamatory statements about the plaintiff. In a recent Ontario decision, Astley v. Verdon, 2011 ONSC 3651, 106 O.R. (3d) 792 (Ont. Sup. Ct.), the court stated at paras. 20 and 21: 20 It is well‑settled law that, in appropriate circumstances, a court may grant an injunction to prevent a defendant from continuing to disseminate defamatory material that affects a plaintiff’s reputation: ... 21 Permanent injunctions have consistently been ordered after findings of defamation where either: (1) there is a likelihood that the defendant will continue to publish defamatory statements despite the finding that he is liable to the plaintiff for defamation; or (2) there is a real possibility that the plaintiff will not receive any compensation, given that enforcement against the defendant of any damage award may not be possible: ... . [Citations omitted]