The quantum of damages in defamation is a matter for the trier of fact, and is governed by all of the circumstances of the case, including the following (Hill v. Church of Scientology of Toronto, 1995 CanLII 59 (SCC), [1995] 2 S.C.R. 1130 at para. 182): (a) The plaintiff's conduct, position and standing; (b) The nature and seriousness of the defamatory statements; (c) The mode and extent of publication; (d) The absence or refusal of any retraction or apology; (e) The whole conduct and motive of the defendant from publication through to judgment; and (f) Any evidence of aggravating or mitigating circumstances.
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