*385.* _Newspapers, Criticisms, Priest._—A newspaper has a right to publish criticisms of the conduct of a priest in certain services held in his church if no false statement of facts is given, since such conduct is a proper subject of discussion; and if such article contains a statement that if certain published accounts of the conduct of the priest are true he acted in an improper manner, etc., it is not libelous because such facts are not true, as it is not an affirmation of the truth thereof. Where the alleged libel was published in a foreign language and the correctness of the translation was disputed, it was an error for the judge to instruct the jury that if the translation introduced in evidence was correct, the defendant was liable, since plaintiff’s right to recover should not be made to depend on the absolute accuracy of the translation.(684) *386.* _Clergyman, Discipline, Tribunals, Testimony, Argument._—What a clergyman says in the administration of the discipline of the church or what is said in tribunals to enforce discipline of the church, including testimony and legitimate argument within the scope of the case, if said in good faith and without malice, is not actionable in the civil courts.(685) *387.* _Physical Discipline, Imprisonment, Courts._—A clergyman who claims to have been slandered by a parishioner can not administer physical discipline nor put the offender under restraint without leaving himself liable for damages for assault and battery or false imprisonment. If the clergyman desires to treat the charge as a church matter, he must go into the church tribunal; otherwise, his proper course is to bring an action for slander in the State court.(686) *388.* _Sermon, False Statement, Crime._—A clergyman may, by words used in a sermon, slander a member of his congregation. However, if he makes no false statement and does not falsely or maliciously charge a crime, what he says in the way of discipline is privileged.(687) The meaning of the words “she is a dirty, vile woman,” can not be extended by innuendo.(688) *389.* _Charges, Robbed, Hypocrite._—Charges that a person has robbed a church or has stolen from a church, are actionable.(689) Also, charging a person with being a hypocrite and using the cloak of religion for unworthy purposes, is slanderous.(690) *390.* _Investigation, Probable Cause._—When a member of a church consents to an investigation on complaint before a person who is not a member, if the complaint was made on probable cause and not under the pretence of exposing the defendant to scorn or obloquy, he could not subsequently bring an action for libel.(691) *391.* _Sacraments._—To publish of a person that he has been deprived of the sacraments of the church to which he belongs, is libelous.(692)