Publication is necessary for defamation. Posting must be intentional or negligent. In this case, publication does not mean giving publicity, but making the statement known to someone other than the defamed one.

If a defendant has made a defamatory statement only to the plaintiff and to no one else, it will not constitute defamation. If he hands it over to someone else who reads it, it will be published by himself and therefore the accused cannot be held responsible, but if he has a duty to send it to someone else, the accused is responsible.

In Pullman v. Closed, [(1891) 1 OS 524, the plaintiff dropped a letter in an open card containing defamatory matter, which is likely to be read by somebody else. It was held that it amounts to publication.

In Theaker v. Richardson, [(1962) 1 All ER 229] It was held that sending something via telegram or postcard that could be read by others can be claimed as publication.

In Delacroix v. Thevenot, [(1817) 2 Stark 63], ii it was observed that if a person knowingly sends something in writing to defame a person in a sealed envelope that will be opened by someone else, then this amounts to a post.

In Sadgrove v. Hole, [(1829) 10 BRC 263] the defendant sent a third person a postcard containing a defamatory statement relating to the plaintiff, but the plaintiff’s name was not mentioned and no stranger unaware of the circumstances would have known to whom he was referring.