LIMITATIONS – defamation proceedings commenced outside limitation period – related proceedings also commenced in Fair Work Commission – burden of proof on plaintiff to show it was not reasonable to commence within time period – burden not discharged – cause of action not maintainable.

DEFAMATION – employee of Commonwealth – alleged misconduct – Intent to Sanction Minute and Statement of Reasons circulated to supervisors and others involved in investigation – defence of qualified privilege made out.

Matthew Richardson appeared for the Commonwealth of Australia.