The plaintiff, a nurse, was injured in a motor-vehicle accident and was taken to a local hospital. She was examined by the defendant, who could find no physical injury other than a few minor bruises. She was discharged from the hospital the next day when she admitted that she “felt fine.” Within 24 hours after her release, she returned to the hospital. She complained to the defendant of painful headaches and remained in hospital for a month. During her second stay in hospital she was examined by three neurosurgeons who could find nothing wrong with her.

On her release from the hospital, she instituted legal proceedings against the parties responsible for her automobile accident, and her solicitor requested a medical opinion from the defendant to support her case.

In response to the solicitor’s request, the defendant wrote two letters that were uncomplimentary and suggested that the plaintiff had not suffered any real physical injury. In addition, the defendant had indicated on the plaintiff’s medical records that the plaintiff was suffering from hypochondriasis.

After her discovery of the uncomplimentary letters and medical reports, the plaintiff brought an action against the defendant for libel.

Examine the arguments that might be raised in this case and identify the defences (if any) to the plaintiff’s claim.