British Lawmakers Look at Rewriting Libel Law - NYTimes.com - http://www.nytimes.com/2009...
Dec 11, 2009
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"English libel law is the opposite of America’s in many ways. In the United States, the plaintiff, or accuser, must prove that the statement in question was false; public officials must also prove that it was made maliciously, with “reckless disregard” for the truth. In England (Scotland has its own system), the burden of proof rests on the defendant, whose statements are presumed false and who has to establish that they are true."
- Frankie Warren