Claire required a reference for a new job. She asked for a letter from her former employer, Alice. Alice wrote that Claire was honest, hard-working, intelligent and pleasant, and would do best in a job with considerable direction and supervision. Since Claire had applied for work in outside sales, she was turned down as the job needed an independent self-starter. Claire sued Alice for libel. Unless Alice can prove the truth of what she wrote, Claire will win. Alice could successfully argue that she had written the letter in good faith and only said what she honestly believed to be true. Alice could successfully raise the defence of absolute privilege Even if what Alice said was true, Claire will win since, if she was not willing to write only positive things, Alice should have declined to write at all