Cohen notes «At first [Westfall's] compositions strike the viewer as well - behaved structures of pattern with decorative correlates in the applied arts... But his visual wit goes beyond mere reference to recent abstract art history. (painters-table.com)
These cases recognize the importance of achieving a proper balance between protecting an individual's reputation and the foundational role of freedom of expression in the development of democratic institutions and values (Grant, at para. 1; Hill, at para. 101)... Interpreting the publication rule to exclude mere references not only accords with a more sophisticated appreciation of Charter values, but also with the dramatic transformation in the technology of communications. (chartercases.com)
On the facts as recited and understood by Collins J in his judgment it did seem surprising that he would find mere reference to an ombudsman complaint to be a killer blow to the whole decision. (newlawjournal.co.uk)