What is the test for qualified privilege?

For qualified privilege to apply, the respondent must have “an interest or a duty, legal, social, or moral, to make [the impugned statements] to the person to whom [those statements are] made”: Hill v. Church of Scientology of Toronto, 1995 CanLII 59 (SCC), [1995] 2 S.C.R. 1130, at para. 143. It is unclear what duty, of that type, the respondent could point to in order to qualify its statements as falling within a situation of qualified privilege, which in any event is rarely available for widely circulated publications Indeed, I note that the respondent did not pursue this defence on the appeal.