The tort of libel is committed through the publication of defamatory words in writing. It is a tort in which the writer or publisher attacks the reputation, integrity, standing and or fidelity of the victim of the publication. However, published words which are considered to be vulgar abuses, will not normally ground an action for libel or slander. What could be regarded as vulgar abuse would however depend on the exact words published, the status of the parties and the circumstances when the publication is made. For instance, abusive words uttered by low class people or motor park drivers and workers which are usually uttered as prelude to a fight, are usually regarded as vulgar abuses as they are normally never taken very seriously and could therefore not ground an action for either slander or libel. See Sketch Publishing Company Ltd. v. Ajagbemokeferi (1989) 1 NWLR (Pt. 100) 678; Nwachukwu v. Nnoremeke (1957) 2 E.R.L.R. 50; and Union Bank of Nigeria Ltd. v. Oredein (1992) 6 NWLR (Pt. 247) 355.
— Akintan, JSC. Iloabachie v Iloabachie (2005) – SC.137/2000