All his historical romantic instincts ensured that he would view it with profound respect or even reverence, but that was something distinct from the business of running the country.6. [82], Both the common law and the Human Rights Act 1998 are domestic sources of rights. [15], In the late 1940s, Churchill wrote and published six volumes of World War II memoirs. [5] He confidently announced after Munich that he had secured "peace for our time".[6]. The BBC also suppressed the fact that 15,000 people protested the prime minister in Trafalgar Square as he returned from Munich in 1938 (10,000 more than welcomed him at 10 Downing Street). By Nivea Serrao November 04, 2016 at 07:17 PM EDT. [325][326][327] In addition, the Charter of Fundamental Rights of the European Union, which has legal effect equivalent to the Treaties following the entry into force of the Treaty of Lisbon,[328] is applicable to Member States when "they are implementing Union law". [36] Further pressure for acceptance came from the British judge and President of the Court, Arnold McNair, 1st Baron McNair, the Secretary General of the Council of Europe Peter Smithers, Terence Higgins MP and various non-governmental organisations. King George VI had evidently been working on Churchills retirement, but his death gave Churchill the perfect reason to stay on.18 Churchill said he would retire on specific dates, but then he found excuses to hang on. As clouds of war darkened over Europe, Britain stood alone against the onslaught. In October 1935 Mussolini launched an attack on Abyssinia. [22], Because of Churchill's health and his evident inability to focus on paperwork, he was not expected to remain in office for more than a year or so, but he constantly delayed resignation until finally his health necessitated it. [9][15] Nevertheless, the initial response of the British public to the Munich agreement was generally favourable. Frank McDonough is a leading proponent of this view of appeasement and describes his book Neville Chamberlain, Appeasement and the British Road to War[81] as a "post revisionist" study. He was briefly succeeded by Frederick Pethick-Lawrence and then by Arthur Greenwood, who had left the war cabinet, from 22 February 1942 until 23 May 1945. Churchill traded the literary rights to his books in return for double the salary he made as Prime Minister. France consulted Britain and lodged protests with the League, but took no action. [51], The Labour Party opposed the Fascist dictators on principle, but until the late 1930s it also opposed rearmament and it had a significant pacifist wing. He was elected a member of Parliament in 1908 and was appointed to the prime minister's cabinet as president of the Board of Trade. This, in turn, led to the great irony of Churchills life. "History extension 2019: Constructing history case study: Appeasement. They met no resistance and were greeted by cheering Austrians. This question burns through Richard Toyes new history, Churchills Empire, and is even seeping into the Oval Office. Labour's leader Clement Attlee and his deputy Arthur Greenwood then joined the meeting, and when asked, they indicated that they must first consult their party's National Executive Committee (then in Bournemouth to prepare for the annual conference), but it was unlikely they could serve in a government led by Chamberlain; they probably would be able to serve under some other Conservative. Chamberlain pursued a policy of appeasement and rearmament. At the same time, Prime Minister Churchill is hearing of his Foreign Secretary Anthony Edens ploy to ask the King to urge him resign. Two years later, he had a similar attack while battling a bout of pneumonia. In legal terms, a type of corporation, the Crown, is the legal embodiment of executive, legislative, and judicial governance in the monarchy of the United Kingdom. That is our policy. [157] The application of the double jeopardy rule was limited by the Criminal Justice Act 2003. He claimed that painting helped him with his powers of observation and memory. 7. Join thought-provoking conversations, follow other Independent readers and see their replies. [60][61], Czechoslovakia did not concern most people until the middle of September 1938, when they began to object to a small democratic state being bullied. [citation needed], In 2002, the Special Immigration Appeals Commission held that indefinite detention under Part 4 was incompatible with the right to non-discrimination under Article 14 ECHR, on the basis that only suspected terrorists who were foreign nationals were subjected to detention, while suspects who were British nationals remained free. Was Churchills moral opposition to Nazism a charade, masking the fact he was merely trying to defend the British Empire from a rival? [citation needed], It was during his opposition years that Churchill twice expounded his views on Ireland to successive Irish ambassadors in London. James P. Levy argues against the outright condemnation of appeasement. It is natural for Parliaments to talk and for the Crown to shine. He then continued: Well do we realize the burdens imposed by sacred duty upon the Sovereign and her family. Churchill remained a member of Parliament until the general election of 1964 when he did not seek reelection. [174] Interception should not be disclosed in judicial proceedings. 381 members voted "aye" in favour of the motion and, apart from the two tellers for the "noes", the wartime coalition was endorsed unanimously. Hitler, an Austrian by birth, had been a pan-German from a very young age and had promoted a Pan-German vision of a Greater German Reich from the beginning of his career in politics. She revered him as many other young people did at that time.2. [275] Second, using threatening, abusive or insulting words or behaviour, including on signs, is an offence if this could make people believe they will suffer immediate unlawful violence,[276] or if it causes or is likely to cause "harassment, alarm or distress. This was kept secret until Churchill spoke of it to a stunned House of Commons a year later. Churchill suffered his final stroke on 10 January 1965. [7] John Locke (16321704), one of the most influential of Enlightenment thinkers, argued that protection of "property" which to him meant "life, liberty and estates" were the very reasons that society existed. In 1954, the English artist Graham Sutherland was commissioned to paint a full-length portrait of Prime Minister Sir Winston Churchill of the United Kingdom. I saw them in Munich. To critics, his steadfast commitment to British imperialism and his withering opposition to independence for India underscored his disdain for other races and cultures. Johns, Michael, "Peace in Our Time: The Spirit of Munich Lives On", Murray, Williamson. ", Cole, Robert A. It was hastily written and has few claims to historical scholarship,[72] but Guilty Men shaped subsequent thinking about appeasement and it is said[73][74] that it contributed to the defeat of the Conservatives in the 1945 general election. [406], There has been a growing awareness of human trafficking as a human rights issue in the UK, in particular the trafficking of women and under-age girls into the UK for forced prostitution. The official biography, Winston S. Churchill, was begun by the former prime minister's son Randolph in the early 1960s; it passed on to Martin Gilbert in 1968, and then into the hands of an American institution, Hillsdale College, some three decades later. The couple had five children together: Diana, Randolph, Sarah, Marigold (who died as a toddler of tonsillitis) and Mary. Schuschnigg complied and appointed Arthur Seyss-Inquart, a pro-Nazi lawyer, as interior minister. Joseph Stalin ruled the Soviet Union for more than two decades, instituting a reign of death and terror while modernizing Russia and helping to defeat Nazism. This table lists the officers appointed to the royal household during the Churchill administration.[43]. Three British journalists, Michael Foot, Frank Owen and Peter Howard, writing under the name of "Cato" in their book Guilty Men, called for the removal from office of 15 public figures they held accountable, including Chamberlain. [300] There is no positive right to healthcare; the National Health Service Act 1977 imposes a duty on the Secretary of State to provide "adequate" healthcare but the courts have not thus far been willing to enforce this duty. Austria became the German province of Ostmark, with Seyss-Inquart as governor. The Crown Colony of the Island of Malta and its Dependencies (commonly known as the Crown Colony of Malta or simply Malta) was the British colony in the Maltese islands, today the modern Republic of Malta.It was established when the Malta Protectorate was transformed into a British Crown colony in 1813, and this was confirmed by the Treaty of Paris in 1814. At Chamberlain's request, Hitler readily signed a peace treaty between the United Kingdom and Germany. Edinburgh Scotland, 5-7 October 2023. [43], The week before Munich, Churchill warned "The partition of Czechoslovakia under pressure from the UK and France amounts to the complete surrender of the Western Democracies to the Nazi threat of force. Beaverbrook, Lyttelton and Woolton were brought in to fill new offices that were created to address current priorities. Nevertheless, the Italian economy suffered. Their offices have rarely, if ever, been recognised as cabinet-level, although some of the office holders here did, at need, occasionally attend cabinet meetings. [232] The Terrorism Act 2006 defines incitement to terrorism as 'direct or indirect encouragement or other inducement' for 'commission, preparation or instigation of acts of terrorism', as well as glorifying terrorist acts (that is 'any form of praise or celebration') punishable with 7 years in prison. "[33], On 1 September 1939, German forces invaded Poland; Britain and France joined the war against Germany, but initially averted serious military involvement during the period known as the Phoney War. Aliens Restriction (Amendment) Act 1919 s 3 prohibits an 'alien' from causing sedition or disaffection among civil population and armed forces. Arthur Greenwood, Labour's deputy leader, was appointed a minister without portfolio. [264] Anomalously it was held in Hubbard v Pitt that an estate agent might be able to sue a group of protestors in the tort of private nuisance for giving out leaflets and displaying placards opposed to it, on the ground that frustrated its business. [22] British leaders committed to the Munich Pact in spite of their awareness of Hitler's vulnerability at the time. The United Kingdom consists of four countries and three distinct legal systems: AW Blumrosen, 'The Profound Influence in America of Lord Mansfield's Decision in Somerset v Stuart' (2007) 13 Texas Wesleyan Law Review 645. Despite the Conservative landslide under Macmillan's leadership in 1959, Churchill's own majority in Woodford fell by more than a thousand. It was led by Winston Churchill, who was appointed Prime Minister by King George VI following the resignation of Neville Chamberlain in the aftermath of the Norway Debate.. At the outset, Churchill formed a five-man war cabinet He also advocated that Britain remain independent from European coalitions. While in the Army, he wrote military reports for the Pioneer Mail and the Daily Telegraph, and two books on his experiences, The Story of the Malakand Field Force (1898) and The River War (1899). With the general election of 1951, Churchill returned to government. The version of events given by Churchill is that Chamberlain's preference for Halifax was obvious (Churchill implies that the spat between Churchill and the Labour benches the previous night had something to do with that); there was a long silence which Halifax eventually broke by saying he did not believe he could lead the government effectively as a member of the House of Lords instead of the House of Commons. Although she argued against the policy of "peace at almost any price"[70] she did not take the personal tone that Guilty Men was to take two years later. Churchill had shown signs of fragile health as early as 1941 when he suffered a heart attack while visiting the White House. [320] It also gives employment tribunals new powers to make recommendations to employers. We can't rule out any option for stopping Putin | Ian Bond", "Kissinger says Ukraine should cede territory to Russia to end war", Oxford Dictionary of National Biography, Proponents and Critics of Appeasement, Ensuring Benevolent Neutrality: The British Government's Appeasement of General Franco during the Spanish Civil War, 19361939, "Geoffrey Dawson, editor of "The Times" (London), and his contribution to the appeasement movement" (PhD dissertation, U of North Texas, 1993) online, German evacuation from Central and Eastern Europe, European foreign policy of the Chamberlain ministry, Oliver Baldwin, 2nd Earl Baldwin of Bewdley, Arthur Baldwin, 3rd Earl Baldwin of Bewdley, 1924 Prime Minister's Resignation Honours, https://en.wikipedia.org/w/index.php?title=Appeasement&oldid=1113831958, History of the foreign relations of the United Kingdom, Articles with Dutch-language sources (nl), Short description is different from Wikidata, Articles with unsourced statements from December 2012, Articles with unsourced statements from April 2014, Articles with unsourced statements from September 2021, Articles with unsourced statements from April 2022, Creative Commons Attribution-ShareAlike License 3.0, Alexandroff A. and Rosecrance R., "Deterrence in 1939,", Beck R.J., "Munich's Lessons Reconsidered" in, Goddard, Stacie E. "The rhetoric of appeasement: Hitler's legitimation and British foreign policy, 193839.". [44] In 1938, the Royal Navy approved appeasement regarding Munich because it calculated that at that moment, Britain lacked the political and military resources to intervene and still maintain an imperial defence capability. ", Peden G. C., "A Matter of Timing: The Economic Background to British Foreign Policy, 19371939,". Maybe I'll buy another horse with an entry in the Irish Derby". Guy La Chambre, the civilian air minister, optimistically informed the government that the air force was capable of stopping the Luftwaffe. The coalition was dissolved in May 1945, following the final defeat of Germany, when the Labour Party decided to withdraw in order to prepare for a general election. A plebiscite was held on 10 April and officially recorded a support of 99.73% of the voters.[12]. He may have been a thug, but he knew a greater thug when he saw one and we may owe our freedom today to this wrinkle in history. [1] The term is most often applied to the foreign policy of the UK governments of Prime Ministers Ramsay MacDonald (in office: 19291935), Stanley Baldwin (in office: 19351937) and (most notably) Neville Chamberlain (in office: 19371940) towards Nazi Germany (from 1933) and Fascist Italy (established in 1922)[2] between 1935 and 1939. [84] In 1999, Christopher Hitchens wrote that Chamberlain "had made a cold calculation that Hitler should be re-armedpartly to encourage his 'tough-minded' solution to the Bolshevik problem in the East". Some of the child spies are aged under 16. The Austrian Chancellor Kurt Schuschnigg wished to pursue ties with Italy, but turned to Czechoslovakia, Yugoslavia and Romania (the Little Entente). Some of the appointees retained offices that they held in former administrations and these are marked in situ with the date of their original appointment. [118], People who are arrested must be brought to a police station as soon as practicable, and there must either be released, charged or detained for questioning. He was so enthusiastic about aviation that he took flying lessons himself to understand firsthand its military potential. [28] On 20 March, just five days after the Nazi occupation of Czechoslovakia, Ribbentrop agreed to meet with Urbys, but not with Kazys kirpa, who was asked to wait in another room. 6 November 1944: Lord Moyne was assassinated in Cairo by Jewish militants. It included Bohemia, Moravia, and Slovakia and had border areas with a majority-German population known as the Sudetenland and areas with significant numbers of other ethnic minorities (notably Hungarians, Poles, and Ruthenes). He saw things in a very romantic and glittering way; perhaps one was looking at it in a rather too mundane way.15 Welcoming The Queen home, Churchill outdid himself, saying: I assign no limits to the reinforcement which this royal journey may have brought to the health, the wisdom, the sanity and the hopefulness of mankind.16, Overshadowing The Queens relationship with Churchill were his deteriorating health and his reluctance to retire. [citation needed], The common law has not traditionally provided effective protection against discrimination, refusing to find that slavery in the colonies was contrary to public policy and not interpreting the word "person" to include women. [237] There is also 'qualified privilege' which gives a defence to defamation, but only if the writer asks the subject for an explanation or contradiction, for any legislative proceedings outside the UK, public enquiries, non-UK government documents, and matters of an international organisation. [40][25][41] Churchill persisted with his view before and after his stroke, but Eisenhower and Dulles continued to discourage him. They were not. [146] A fair hearing implies that each party has the opportunity to present their own case to an impartial tribunal. One of the most striking findings of Toyes research is that they really didnt: even at the time, Churchill was seen as at the most brutal and brutish end of the British imperialist spectrum. France was anxious to placate Mussolini so as to keep him away from an alliance with Germany. His fascist agenda led to World War II and the deaths of at least 11 million people, including some six million Jews. [104] In practice, every power of the police or the state to maintain order and security 'inevitably means a corresponding reduction in the liberty of the individual',[105] and the UK has among the highest spending on policing in the world. His successor was not in the war cabinet. [21][22] The CDC was established by Churchill as soon as he took office. [77], Human rights in Scotland are given legal effect through the Scotland Act 1998. Churchills youngest daughter Mary told her own daughter Emma Soames: The Queen very quickly captivated him, he fell under her spell. However most television channels are funded through advertising revenue. [1], Dissatisfaction with Chamberlain's leadership became widespread in the spring of 1940 after Germany successfully invaded Norway. John Lithgow is an American actor. Vuilliamy, E., "Bosnia: The Crime of Appeasement", Penny McRae, "West appeasing China on Tibet, says PM-in-exile", AFP, 15 September 2009, agreed to concede two-thirds of Abyssinia to Italy, Non-intervention in the Spanish Civil War, President of the United States of America, Confidence and security-building measures, https://doi.org/10.1080/07075332.2018.1428211, "Oxford Dictionary of National Biography", "The Labour Party and the Economics of Rearmament, 19351939", Richard Overy, "Parting with Pacifism: In the Mid-1930s Many Millions of British People Voted Overwhelmingly against Any Return to Conflict. Even his startled doctor, Lord Moran, said of other races: Winston thinks only of the colour of their skin.. [257] Although Highways Act 1980 section 137 makes it an offence to obstruct a highway,[258] in DPP v Jones the House of Lords held that protestors who assembled on roads around Stonehenge despite police ordering them to disperse from a four-mile radius,[259] could not be lawfully arrested or convicted, because their occupation was 'not inconsistent with the primary right of the public to pass and repass. During Operation Demetrius, for instance, a total of 1,981 people were interned without trial,[396] of whom only 107 were loyalists, and no loyalists were arrested until 1973, 2 years after the introduction of internment. [71] The appointment of Churchill as Prime Minister after the Norway Debate hardened opinion against appeasement and encouraged the search for those responsible. Also protected in international law,[245] the European Convention on Human Rights article 11 states: 'Everyone has the right to freedom of peaceful assembly and to freedom of association with others' including joining 'trade unions for the protection of' their interests. In Britain, it was thought that the Germans were merely walking into "their own backyard". [8], During the 18th century, the landmark case of Entick v Carrington, following Locke almost exactly, established that the state and government could do nothing that is not expressly provided for by law, and that people could do anything but that which is prohibited by law. Appeasement in an international context is a diplomatic policy of making political, material, or territorial concessions to an aggressive power in order to avoid conflict. Mary Soames, ed., Speaking for Themselves: The Personal Letters of Winston and Clementine Churchill (Toronto: Doubleday, 1998), p. 328. It could be said that he believed sincerely that the objectives of Hitler and Mussolini were limited and that the settlement of their grievances would protect the world from war; for safety, military and air power should be strengthened. She studied the detention camps for five years for her remarkable book Britains Gulag: The Brutal End of Empire in Kenya, explains the tactics adopted under Churchill to crush the local drive for independence. [115] Otherwise, a justice of the peace may issue a warrant for arrest, require attendance at court, in writing, and it can be executed by a constable. While there are loose limits on cross-ownership of TV and newspapers,[220] there is no regulation yet separate advertising business and internet media platforms where their interests conflict with public goals. In a meeting in Tehran (1943), at the Yalta Conference (1945) and the Potsdam Conference (1945), Churchill collaborated with the two leaders to develop a united strategy against the Axis Powers and helped craft the postwar world with the United Nations as its centerpiece. In his biography of Churchill, Roy Jenkins described the Churchill cabinet as one "for winning", while the former Chamberlain cabinet was one "for losing". "[41] Amongst Conservatives, Churchill was unusual in believing that Germany menaced freedom and democracy, that British rearmament should proceed more rapidly and that Germany should be resisted over Czechoslovakia. Gary Oldman took his turn by undergoing an eye-popping physical transformation to become the iconic statesman in Darkest Hour. Within the Churchill papers, the earliest recorded reference to the future queen is found in a letter to his wife that Churchill wrote from Balmoral Castle on 25 September 1928, in which Churchill anticipates the destiny of the future sovereign: There is no one here at all except the Family, the Household & Queen Elizabethaged 2. [161] While rights to liberty and a fair trial also protect against unjustified search or seizure, the European Convention on Human Rights article 8 enshrines the right to one's 'private and family life', 'home' and 'correspondence' unless interference is 'in accordance with the law' and 'necessary in a democratic society' for public security, safety, economic well-being, preventing crime, protecting health or morals or rights of others.[162]. Only the manifestation of a belief can be limited on justifiable legal grounds as strictly necessary in a democracy. [15] Churchill had happy childhood memories of Ireland from his father's time there as private secretary to the lord lieutenant of Ireland from 1876 to 1880. [180] The meaning of 'consent' requires more than the basic rules for commercial contracts, and must be clearly and distinctly identifiable, and revocable at any time. A trade union, central and local government appear unable to bring defamation claims: KD Ewing, 'The Implications of Wilson and Palmer' (2003) 32(1) Industrial Law Journal 1-22, AL Goodhart, 'Public Meetings and Processions' (1937) 6 CLJ 161, 169, Criminal Justice and Public Order Act 1994 ss 61-77, also, 2023 Periodic Review of Westminster constituencies, Political Parties, Elections and Referendums Act 2000, Scottish Parliament constituencies and electoral regions, Senedd constituencies and electoral regions, Measure of the National Assembly for Wales, Metropolitan and non-metropolitan counties, Saint Helena, Ascension and Tristan da Cunha, South Georgia and the South Sandwich Islands, Foreign, Commonwealth and Development Office, Post-Brexit United Kingdom relations with the European Union, Declaration of the Rights of Man and of the Citizen, International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights, European Court and Commission of Human Rights, Secretary General of the Council of Europe, Section Thirty-three of the Canadian Charter of Rights and Freedoms, Human Fertilisation and Embryology Act 1990, Caitlin Reilly and Jamieson Wilson v Secretary of State for Work and Pensions, European Convention on Human Rights article 5, Rugby Football Union v Consolidated Information Services Ltd, Freedom of religion in the United Kingdom, Criminal Justice and Immigration Act 2008, Employment Equality (Religion or Belief) Regulations 2003, European Convention on Human Rights article 11, Gillick v West Norfolk Area Health Authority, Health Services and Public Health Act 1968, Social Security Contributions and Benefits Act 1992, Employment Equality (Sexual Orientation) Regulations 2003, Employment Equality (Age) Regulations 2006, House of Commons (Removal of Clergy Disqualification) Act 2001, Charter of Fundamental Rights of the European Union, Convention on the Elimination of All Forms of Racial Discrimination, Convention on the Elimination of All Forms of Discrimination Against Women, United Nations Convention Against Torture, Optional Protocol on the Involvement of Children in Armed Conflict, Optional Protocol on the sale of children, child prostitution and child pornography, European Convention for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment, Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, European Charter for Regional or Minority Languages, Convention on the Rights of Persons with Disabilities, Framework Convention for the Protection of National Minorities, Convention on Action against Trafficking in Human Beings, collusion between loyalist paramilitaries and British security forces, Anti-terrorism, Crime and Security Act 2001, A and Others v. Secretary of State for the Home Department, Anti-Terrorism, Crime and Security Act 2001, Council of Europe Convention on Action against Trafficking in Human Beings, Jobseekers (Back to Work Schemes) Act 2013, International Co-ordinating Committee of NHRIs, Committee on the Administration of Justice, "The UK and the European Court of Human Rights", "Magna Carta and contemporary constitutional change", A Vindication of the Rights of Woman: with Strictures on Political and Moral Subjects, Declaration of the Rights of Woman and of the Female Citizen, R (HS2 Action Alliance Ltd) v Secretary of State for Transport, Kadi and Al Barakaat International Foundation v Council and Commission, "UK to appoint first human rights ambassador", "Lords Hansard text for 3 Nov 1997 (171103-03)", "Lords Hansard text for 29 Jan 1998 (180129-27)", "Lords Hansard text for 18 Nov 1997 (171118-15)", "Orders of the Day Human Rights Bill [Lords]: 16 Feb 1998: House of Commons debates", "House of Commons Hansard Debates for 3 Jun 1998 (pt 33)", "House of Commons Hansard Debates for 3 Jun 1998 (pt 40)", "House of Commons Hansard Debates for 21 Oct 1998 (pt 43)", "Protecting and promoting human rights at home and abroad", David Cameron: Scrap the Human Rights Act, "Consequences 'dire' if Human Rights Act ditched, more than 50 groups warn", Van Colle v Chief Constable of Hertfordshire, "Government fail to overturn Poundland work scheme ruling", Hill v Chief Constable of South Yorkshire, Kuddus v Chief Constable of Leicestershire Constabulary, Police Reform and Social Responsibility Act 2011, Privacy International v Foreign Secretary, Charter of Fundamental Rights of the European Union 2000, Associated Newspapers Ltd v Prince of Wales, "Law ending exclusively male royal succession now law", Jonathan Harmsworth, 4th Viscount Rothermere, R (News Media Association) v Press Recognition Panel, Attorney-General v Guardian Newspapers Ltd (No. [25][42] Churchill met Eisenhower to no avail at the Bermuda Conference in December 1953[43] and in June/July 1954 at the White House. That this House desire to take this opportunity of marking the forthcoming retirement of the right honourable Gentleman the Member for Woodford by putting on record its unbounded admiration and gratitude for his services to Parliament, to the nation and to the world; remembers, above all, his inspiration of the British people when they stood alone, and his leadership until victory was won; and offers its grateful thanks to the right honourable Gentleman for these outstanding services to this House and to the nation. [230] The same idea extends to religious hatred, sexual orientation and in practice disability. In August 1938, General Ludwig Beck relayed a message to Lord Halifax explaining that most of the German General Staff were preparing a coup against the Fuhrer, but would only attack with "proof that England will fight if Czechoslovakia is attacked". [234], The truth is always a defence for stating something factual, and a defendant may always show their statement 'is substantially true', or that they made a statement of honest opinion, rather than an assertion of fact.
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