Little excuse is needed to touch on the law of libel and slander, owing to the constant flow of diverting cases brought in connection with this branch of legal activity. The King _v._ Mylius, arising out of a personal attack on King George; Howard de Walden _v._ Lewis,[13] an extraordinary instance of libel; De Forest _v._ Milner and De Forest _v._ Lady Gerard (two actions for slander) were among the notorious batch to be heard in the Royal Courts of Justice during Hilary Term, 1911. There are many interesting points associated with libel and slander. Even the purely technical aspect of the subjects is often entertaining. Everyday life is full of slanders, perfect slanders too, many of them, but they are frequently, if not generally, of a non-actionable character, unless, of course, “special damage” protrudes itself into the situation in point. According to Mr. Hugh Fraser, an authority on the subject,[14] or subjects, libel and slander are definable in this way: “A defamatory statement is a statement concerning any person which exposes him to hatred, ridicule, or contempt, or which causes him to be shunned, or avoided, or which has a tendency to injure him in his office, profession or trade. Such a statement, if in writing, printing, or other permanent form, is a libel; if in spoken words or significant gestures, a slander.” “A statue, caricature, effigy, chalk marks on a wall, ‘signs or pictures, as by fixing up a gallows against a man’s door, or by painting him in a shameful or ignominious manner,’ may constitute a libel.” If a plaintiff alleges “that he is the person referred to as the villain in a book or story which purports to be a work of fiction, he must prove (_a_) that the author meant to refer to him, and (_b_) that the work was so written that those knowing the plaintiff would reasonably infer that he was intended.” To say of a barrister that he knows no law is actionable _per se_.[15] To impute incapacity to a journalist is also, it would seem, actionable _per se_. “In accordance with the common law principle that husband and wife are one person, ‘the uttering of a libel by a husband to his wife is no publication.’ ‘For many purposes they are,’ however, ‘essentially distinct and different persons, and, among others, for the purpose of having the honour and feelings of the husband assailed and injured by acts or communications made to the wife.’ Thus it has been held that sending a defamatory letter to a wife about her husband is sufficient publication.”