In the past few years there has been considerable development in Commonwealth countries in the law of qualified privilege as it relates to political communication. Australia was the first to adopt an approach inconsistent with earlier authorities, in the High Court decision of Lange v ABC. The former Prime Minister of New Zealand also presented the opportunity for the New Zealand Court of Appeal to follow suit with their decision in Lange v Atkinson. This case proceeded to appeal in the Privy Council and the decision was handed down at the same time as the English decision of Reynolds v Times Newspapers Ltd. The latest instalment in the political communication saga is the New Zealand Court of Appeal’s reconsideration of Lange v Atkinson.