At a social club meeting that was held to discuss an environmental problem in a community, Brown made a speech in favour of a particular course of action that he thought the club should follow. Smith, who did not like the suggestions made by Brown, also made a short speech in which he called Brown an "idiot," and his suggestions "rubbish." Unless it was true that Brown was an "idiot," Smith made a defamatory statement which slandered Brown's reputation.