Even when modernizing the law of comment (WIC Radio & Mair v Simpson [2008] 2 SCR 420) and creating a new “public interest responsible communication” defence (Grant v Torstar Corp [2009] SCC 61) the court failed to take the step of importing Charter analysis or standards into the common law[12] As to the English solution of Reynolds, Eady J comments sadly that the Reynolds defence “seems hardly ever to be used in litigation. [read post]