-1432. The rule that persons relying on the defence are liable unless they discharge the onus of proving lack of knowledge and the absence of negligence indicates that they must in principle be publishers, albeit in a subordinate role, for otherwise they could not be held liable at all since a fundamental constituent of the tort would be missing. On this basis, it may perhaps be preferable to refer to those playing a subordinate role in the publication process as “subordinate publishers” rather than “subordinate distributors” as they are often called. 33. In the present appeal, one of the main issues dividing the parties is whether the respondents are eligible to rely on the innocent dissemination defence or whether they are first or main publishers to whom it does not apply. E. 34. Notice boards and graffiti A further set of legal principles which featured prominently at the hearing of this appeal arises out of the line of cases invoked by the respondents involving actions brought against the owners or occupiers of premises in which unauthorised third parties had affixed defamatory statements on a notice board or scrawled such statements as graffiti on its walls. 35. That line of authorities begins with the decision of the English Court of Appeal in Byrne v Deane.31 There, a libel action was brought against the proprietors of a golf club in respect of a typewritten sheet of paper containing an allegedly defamatory statement set in verse which someone pinned onto a notice board visible to members using the club. The relevant question was whether the club’s proprietors could be held to have acted as publishers of that statement. It was a rule of the club that the posting of notices in the club premises without the consent of the club secretary was not allowed. One of the defendants was the club secretary. She admitted that she had read the statement but allowed it to 31 [1937] 1 KB 818.