The question is raised by the quotation cited as to whether it is now necessary or wise to attempt a statutory reformulation of that aspect of the law, either along the lines of Reynolds or along the lines of Australian and New Zealand cases, the approach of which was rejected by Mr. Justice Ó Caoimh. It could be argued that the decision in the Blom-Cooper case delivers in part on the Government's stated intention to align the Irish law of defamation with defamation laws in comparable common law states. On the other hand it could be argued that the Reynolds formula suffers from a good deal of uncertainty and that a clear statutory reformulation is desirable to make the developing common law in this area more certain. This latter argument presumes that there is a clear statutory reformulation available which would be sufficiently flexible to allow further development and qualification of the privilege. I have not come to any fixed conclusion as to whether this matter should be the subject of express legislation. I can see arguments both ways.