4.

Ad paragraph 7
The contents herein are not in dispute.

5.

Ad paragraph 8
The contents herein are disputed and Defendant’s state that the said
article stated that Ambrose Mahlangu alleges that Gelane Simelane
was his daughter.

6.

Ad paragraph 9
The Defendant denies the allegations that the article was wrongful
and defamatory to Plaintiff. Defendant pleads that:6.1

The article was in essence true

6.2

The said publication was to the benefit of the public.

Alternatively
7

The Defendant pleads that the publication of the article was not
unlawful in that:7.1

Defendants were unaware of the falsity of any averments in
the articles, in that Defendants relied on the claim by Mr
Ambrose Mahlangu,

7.2

Defendants did not publish the article recklessly. That is not
caring whether the contents of such article were true or false,
the facts the Defendants rely on and in this context are the
contents of interview report of Mr. Mahlangu confirming the
Plaintiff as his daughter.

7.3

Defendants were not negligent in publishing the article, in that
attempts were made to contact Plaintiff for her comments on
the claims by Mr Mahlangu, however the Plaintiff did not
answer her phone or respond to messages left with her
secretary.

7.4

In view of the facts alleged the publication was objectively
reasonable.

7.5

The articles were consequently published without animus.
injurlandi.

12

Select target paragraph3