While there is no common law duty to provide a reference, the Supreme Court of Canada has held that a refusal to do so may constitute "conduct that is unfair or is in bad faith" with respect to a wrongful dismissal, and thus "indicative of the type of conduct that ought to merit compensation by way of an addition to the notice period." There is a duty of care to ensure that, where one is provided, it is accurate and fair and not give a misleading impression, as held by the House of Lords in "Spring v Guardian Assurance plc". If an employer goes beyond what a reference should contain, or if it gives inaccurate or misleading information, liability may arise in the areas of breach of statutory duty, negligent misstatement, deceit, defamation or malicious falsehood. It does not matter what form the reference might take.