Simpkins v. Snow, 139 N.H. 735, 740, 661 A.2d 772 (1995) (quoting Chagnon v. Union Leader Corp., 103 N.H. 426, 437, 174 A.2d 825 (1961)). In Jones v. Walsh, 107 N.H. 379, 222 A.2d 830 (1966), the New Hampshire Supreme Court noted the applicability of such a privilege “ ‘when the circumstances induce a correct or reasonable belief that (a) facts exist which affect a sufficiently important interest of the publisher, and (b) the recipient’s knowledge of the defamatory matter will be of service in’ the lawful protection of the interest,” ’ provided the recipient has a social or legal duty which is likely to prove useful in protecting the interest. Id. at 381, 222 A.2d 830 (quoting Restatement of Torts § 594 (1934)); see also Supry v. Bolduc, 112 N.H. 274, 276-77, 293 A.2d 767 (1972) (<HOLDING>). A number of courts have recognized a similar
recognizing privilege holding that a zoning ordinance impinging upon a landowners desired use of his property does not offend substantive due process norms so long as the regulation is not clearly arbitrary and unreasonable having no substantial relation to the public health safety morals or general welfare holding that placement of property in baltimore countys rc4 resource conservation zone did not constitute a deprivation of the landowners constitutional rights to either equal protection or substantive due process recognizing privilege for adjoining landowners defamatory statements about plaintiff to zoning board given landowners private interest in the protection of her property to advance holding that where a zoning board had no authority under state law to take certain actions with respect to a protected property interest a trier of fact could conclude that there was no rational basis for the towns zoning boards actions and that as a result the zoning board violated appellants rights to substantive due process