General damages for harm to one’s reputation are presumed from the very publication of the false statements and an assessment of damages takes into account the following factors: the nature and circumstances of the publication of the libel, the nature and position of the victim of the libel, the possible effects of the libel upon the life of the plaintiff and the actions and motivations of the defendants (Hill v. Church of Scientology of Toronto 1995 CanLII 59 (SCC), [1995] 2 SCR 1130 at para 182).
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