> Allowable defences are justification (i.e. the truth of the statement), fair comment (i.e., whether the statement was a view that a reasonable person could have held), and privilege (i.e., whether the statements were made in Parliament or in court, or whether they were fair reports of allegations in the public interest).
> An offer of amends is a barrier to litigation.
> A defamatory statement is presumed to be false, unless the defendant can prove its truth.
> Furthermore, to collect compensatory damages, a public official or public figure must prove actual malice (knowing falsity or reckless disregard for the truth). A private individual must only prove negligence (not exercising due care) to collect compensatory damages. In order to collect punitive damages, all individuals must prove actual malice.
In the UK truth is still a defense, but the difference is that the burden of proving truth is on the defendant rather than the plaintiff (like in the USA).
In the USA. In the UK, the opposite.