true) to be a valid defence, Recognising reasonable publication on matters of public concern as a valid defence, and Ensuring that defamation may only be addressed by the legal system as a tort. In most of Europe, article 10 of the European Convention on Human Rights permits restrictions on freedom of speech when necessary to protect the reputation or rights of others. Additionally, restrictions of freedom of expression and other rights guaranteed by international human rights laws (including the European Convention on Human Rights (ECHR)) and by the constitutions of a variety of countries are subject to some variation of the three-part test recognised by the United Nations Human Rights Committee which requires that limitations be: 1) "provided by law that is clear and accessible to everyone", 2) "proven to be necessary and legitimate to protect the rights or reputations of others", and 3) "proportionate and the least restrictive to achieve the purported aim". This test is analogous to the Oakes Test applied domestically by the Supreme Court of Canada in assessing whether limitations on constitutional rights are "demonstrably justifiable in a free and democratic society" under Section 1 of the Canadian Charter of Rights and Freedoms, the "necessary in a democratic society" test applied by the European Court of Human Rights in assessing limitations on rights under the ECHR, Section 36 of the post-Apartheid Constitution of South Africa, and Section 24 of the 2010 Constitution of Kenya. Aside from it being a familiar concept to those studying or knowing law, defamation, or "slander", is also known as a "smear campaign" in psychology. Those who suffer from narcissism, sociopathy, and psychopathy use it as a weapon to discredit their victims, typically when they feel you are about to expose them, or are dangerous, but oftentimes it can happen with no known motive beyond psychological projection. Defamation as a tort While each legal tradition approaches defamation differently, it is typically regarded as a tort for which the offended party can take civil action. The range of remedies available to successful plaintiffs in defamation cases varies between jurisdictions and range from damages to court orders requiring the defendant to retract the offending statement or to publish a correction or an apology. Common law Background Modern defamation in common law jurisdictions are historically derived from English defamation law. English law allows actions for libel to be brought in the High Court for any