Kiefel Keane Gleeson CJ J J 7. "without reference to the precise degree in which the defendant has been instrumental to such publication; since, if he has intentionally lent his assistance to its existence for the purpose of being published, his instrumentality is evidence to show a publication by him". Starkie23 said that all persons who: 25 "are in any degree accessory to the publication of a libel, and by any means whatever conduce to the publication, are to be considered as principals in the act of publication". 26 Part of the quotation from Folkard ("has intentionally lent his assistance to its existence for the purpose of being published") is relied on by the appellants as supporting their argument that for a person to be a publisher they must know of the relevant defamatory matter and intend to convey it. The argument is inconsistent with the common law rule relating to publication and, as shall be explained, it derives no support from what was said in Webb v Bloch. 27 An action for defamation does not require proof of fault. Defamation is a tort of strict liability, in the sense that a defendant may be liable even though no injury to reputation was intended and the defendant acted with reasonable care 24. The intention of the author of the defamatory matter is not relevant 25 because the actionable wrong is the publication. It is often persons other than the author who are liable as publisher. A publisher's liability does not depend upon their knowledge of the defamatory matter which is being communicated or their intention to communicate it. 28 The liability of a person as a publisher "depends upon mere communication of the defamatory matter to a third person", Dixon J said26 in Lee v Wilson & Mackinnon. No question as to the knowledge or intention of the publisher arises. His Honour said "[t]he communication may be quite unintentional, and the publisher may be unaware of the defamatory matter", but the person 23 Starkie, A Treatise on the Law of Slander and Libel, 2nd ed (1830), vol II at 225 (emphasis added by Isaacs J). 24 Dow Jones & Co Inc v Gutnick (2002) 210 CLR 575 at 600 [25], referring to Lee v Wilson & Mackinnon (1934) 51 CLR 276. 25 Lee v Wilson & Mackinnon (1934) 51 CLR 276 at 287 per Dixon J. 26 (1934) 51 CLR 276 at 288.