Andrea required a reference for a new job. She asked for a letter from her former employer, Pat. Pat wrote that Andrea was honest, hard$-$working, intelligent and pleasant, and would do best in a job with considerable direction and supervision. Since Andrea had applied for work in outside sales, she was turned down as the job needed an independent self$-$starter. Andrea sued Pat for libel.

Pat's freedom of speech must be protected even at the expense of Andrea's right to protect her reputation so$,$ even if Pat was not being totally truthful, Andrea will lose

Even if what Pat said was true, Andrea will win since, if she was not willing to write only positive things. Anne should have declined to write at all.

Pat could successfully argue that she had written the letter in good faith and only said what she honestly believed to be true

Pat could successfully raise the defence of absolute privilege.