[160] The same can be said of hate speech allegations. They refer to objectively Code, R.S.C. 1985, c. C-46, s. 319(2)). Such speech exposes members of an identifiable group to extreme and deep-felt emotions of detestation and vilification (Whatcott, at para. 59; Keegstra, at pp. 777-78). It “lays the groundwork for later, broad attacks on vulnerable groups. These attacks can range from discrimination, to ostracism, segregation, deportation, violence and, in the most extreme cases, to genocide” (Whatcott, at para. 74). Regardless of whether such conduct is characterized as a criminal offence under the Criminal Code or as the subject matter of a human rights complaint, accusing a person of having “tip toed quite far into hate speech” or having promoted hatred against an identifiable group is extremely damaging to that person’s reputation. In my opinion, the Court of Appeal was right in noting that such an accusation “can inflict serious reputational harm” (para. 68). [161] Second, the chambers judge did not consider the absence of an apology from Mr. Hansman, which is another aggravating factor increasing Mr. Neufeld’s harm (Barrick Gold Corp. v. Lopehandia (2004), 71 O.R. (3d) 416 (C.A.), at para. 51). [162] Third, the chambers judge did not take into account the stature of Mr. Hansman, who, at all relevant times, was acting as the president of the BCTF. This is likely to have magnified Mr. Neufeld’s harm. Indeed, the “greater the reputation of the defendant, the greater the impact the defamation can be expected to have on the plaintiff” (Downard, at §14.01[2][g]; Bent, at para. 161). 2023 SCC 14 (CanLII) and undeniably abhorrent conduct that can give rise to criminal prosecution (Criminal