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Defamation/slander/libel kind of thing with damages estimated based on anticipated earning potential over the course of time you might have been employed by the job they inhibited you from getting. That means that HR or whoever is called for the reference needs to be 100% accurate and provably correct about every single thing they say about the former employee.
From a risk management viewpoint for the company there is basically no gain whatsoever for preventing an employee getting another job, it requires flawless execution, often from random people in HR, and the potential downside is the above, which could be million(s)-dollar damages.
Basically: a bad referral is very high risk, minimal/no upside, and tremendous downside. HR simply reports demonstrable facts (whether employed at the company, from when to when), none of which is subject to interpretation.
If you've REALLY pissed someone off in HR and they want to give you a bad reference, the most they might do is state yes they worked here from X to Y and ask the potential employer if they have other applicants, but even that is just pointless risk from the standpoint of the company.