The invention of the printing press led to easy production and circulation of political tracts and this heightened the fear of seditious libel and led to the establishment of the court of the Star Chamber to affirm and protect royal authority. The court of Star Chamber began punishing any erected that appears to the court capable of bringing the. government to disrepute and since such publications tended to undermine the legitimate government, its truth was immaterial. In fact, “the greater the truth the greater the libel” since the exposure of the truth was more likely to lead to government downfall or a breach of peace. Historically, criminalizing defamation therefore was born out of the need to prevent breaches of peace / public order and secondly to preserve state security. See the cases ofR v Holbrock, (1878) 4 QBD 42 and R v Labouchare, (1884) 12 QBD 320 The public order issue arose out of the tendency of the defamed to draw his sword for a duel in order to defend his integrity and in so doing disrupt public peace. This situation however no longer arises in the modern era where there are established judicial fora for individuals to litigate civil wrongs. As pointed out by Lord Diplock in the case of Gleaves v. Deakin, [1980] AC 477 (at page 482-483). “The original justification for the emergence of the common law offence of defamatory libel in a more primitive age was the prevention of disorder... The reason for creating the offence was to provide the victim with the means of securing the punishment of his defamer by peaceful pracess of the law instead of resorting to personal violence to obtain revenge. 36