Marlon and Peter Who Are Alone in an Office Together

Marlon and Peter who are alone in an office together, are having an argument during the course of which Marlon says to Peter: "You are the lowest form of a thief". Marlon does not have any knowledge of Peter being a thief. Which of the following is TRUE?

A) Marlon has not committed a tort
B) Marlon has not committed a tort because words said in the heat of an argument are not actionable.
C) If Peter sues Marlon for defamation, Marlon can successfully rely on the defence of absolute privilege.
D) If Peter sues Marlon for defamation, Marlon can successfully rely on the defence of qualified privilege.
E) Peter can sue Marlon for defamation because Marlon has made an untrue statement about him.