Carter v. B.C. Federation of Foster Parents Assn. Page 13 (It is to be noted that the English cases he refers to in that passage address the issue of innocent dissemination as opposed to a publication issue.) Similarly, in Basse v. Toronto Star Newspapers Ltd. (1983), 44 O.R. (2d) 164 at 165, 4 D.L.R. (4th) 381 (H.C.), Montgomery J. held, "[e]very republication of a libel is a new libel". The Supreme Court of Canada referred to the Brunswick case in McNicholl v. Grandy, [1931] S.C.R. 696 at 699, [1932] 1 D.L.R. 225, but merely used the case as an example of the low standard required for publication to be found. [19] There can be a potential injustice if a plaintiff is allowed to mount a series of lawsuits based upon a single article, but the courts have the power using their abuse of process jurisdiction to deal with such a course of action: see Thomson v. Lambert, [1938] S.C.R. 253, 2 D.L.R. 545. A similar approach was taken by the English Court of Appeal in the recent case of Jameel v. Dow Jones & Co. Inc., [2005] 2 W.L.R. 1614 (H.L.), where the court said at para. 56: We do not believe that Duke of Brunswick v. Harmer, 14 Q.B. 185 could today have survived an application to strike out for abuse of process. The Duke himself procured the republication to his agent of an article published many years before for the sole purpose of bringing legal proceedings that would not be met by a plea of limitation. If his agent read the article he is unlikely to have thought the Duke much, if any, the worse for it and, to the extent that he did, the Duke brought this on his own head. He acquired a technical cause of action but we would today condemn the entire exercise as an abuse of process. 2005 BCCA 398 (CanLII) had no reason to suspect they were libellous. See Emmens v. Pottle (1886) 16 Q.B.D. 354, 55 L.J.Q.B. 51; and Vizetelly v. Mudie's Select Library [1900] 2 Q.B. 170, 69 L.J.Q.B. 6456.