Ivor Callely (Fianna Fail)

In a similar vein, a matter can be presented by way of fact and can therefore be deemed to be fair and reasonable. However, while subsection (4)(d) refers to the "extent of publication", I am not sure this covers the manner in which a publication is presented, which is also an issue that causes difficulties and complications.

The manner in which an article is presented can give a reflection that would, particularly when it is thrown into the public arena, create a new discussion on the issue. Whereas the publisher may state that what has been published is fact, and is fair and reasonable, the manner in which it is presented would not reflect what is stated in this section.