If memory serves, in the U.K., malice need not be shown by the plaintiff to prove libel.
More than malice needs to be proven to succeed in a libel action. For examples, the statement cant be a statement of mere opinion (or of obvious parody, etc.), and the plaintiff must suffer and prove some sort of damage as a result. Even with malice, it cant just be malice as we laymen might think of it. For example, Richard could write and publish something in Genii that he really hoped would hurt the person (theres your malice), but assuming Richard (a) didnt know the statement to be false and (b) had really researched the statement of fact, with the result being that nothing in the research really jumped out at him as disproving the statement he was making, the guy suing Richard would almost certainly not win the libel case. Ironically, malice (as commonly defined) has practically nothing to do with winning a libel case. Damn lawyers ... :whack: