Kerala High Court hass held that,

Once a statement has been filed in a court of law, that statement can be taken as published and if such a statement amounts to per se defamatory, it is the duly of the accused to establish that they are justified in making such a statement under any of the exceptions to Section 499 I.P.C.

Citations: [2011 KCCR 1 230], [2008 SCC ONLINE KAR 758], [2006 (2) KLT 122]

Indiankanoon.org or Casemine link: https://indiankanoon.org/doc/1547517/

The Index for Defamation Judgments is here.

Reproduced in accordance with Section 52(q) of the Copyright Act 1957 (India) from main.sci.gov.in/judgments, judis.nic.in, lobis.nic.in, indiacode.nic.in and other Indian High Court and District Court Websites such as ecourts.gov.in