It is not a true innuendo to repeat the obvious meaning of defamatory words in other language or in an embroidered or exaggerated way. Otherwise an ingenious pleader could perplex the Judge and jury and harry the defendant by ringing the changes on the same words, creating numerous different causes of action, each requiring a separate verdict. A true innuendo relies on a conjunction of the words used and some extrinsic fact. Thus, it is defamatory in itself to say that a man’s affairs are being investigated by the Fraud Squad: but the statement does not support the innuendo that those affairs are being carried on fraudulently. Conversely, the statement ‘X is a good advertiser’ is innocent in itself, but carries a libelous innuendo if published to persons, who know the extrinsic fact that X is an eminent member of the Bar.” R.F.V Heuston, Salmond on the Law of Torts 149 (17th ed. 1977). The example about lawyers’ advertising no longer has relevance to American law.” [25] The foregoing goes to show the complexity of an innuendo, as opposed to ordinary words used in a different language or embroidered form to explain the meaning of defamatory words and which words or implication thereof, can be easily understood by the reasonable person. [26] I say this because in the case of Argus Printing and Publishing Co Ltd v Esselen’s Estate (Supra) the headnotes espouse the applicable test in determining whether the words of a publication are defamatory per se or an innuendo, in the following terms:“The basic criterion for adjudicating in an exception to the Particulars of Claim in an action for damages, whether the words complained of are reasonably capable of conveying a defamatory meaning, is whether a reasonable person of ordinary intelligence might reasonably understand the words of the article to convey a meaning defamatory of the Plaintiff. The test is an objective one. In the absence of an innuendo, the reasonable person of ordinary intelligence is taken to understand the words alleged to be defamatory in their natural and ordinary meaning. In determining this natural and ordinary meaning the court must take into account not only what the words expressly say, but also what they imply----- It must be emphasized that such an implied meaning has nothing to do with innuendo, which relates to a secondary or unusual defamatory meaning which can be 16