What is the history of a defamation action against the Church of Scientology?

Canada (Federal), Canada

The following excerpt is from Botiuk v. Toronto Free Press Publications Ltd., [1995] 3 SCR 3, 1995 CanLII 60 (SCC):

61 The nature and history of the action for defamation were discussed in Hill v. Church of Scientology of Toronto, 1995 CanLII 59 (SCC), [1995] 2 S.C.R. 1130.

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