International Comparisons
The rule that somebody alleging defamation should have to prove untruth, rather than that the defendant should have to prove the truth of a statement stood as a departure from the previous common law. In England, the development was specifically rejected in Derbyshire County Council v. Times Newspapers Ltd and it was also rejected in Canada in Hill v. Church of Scientology of Toronto and more recently in Grant v. Torstar Corp. However in Australia, the outcome of the case was followed in Theophanous v. The Herald & Weekly Times Ltd.
Read more about this topic: New York Times Co. V. Sullivan
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