Bulletin Co. v Sheppard

Bulletin Co. v Sheppard

On the proved facts and in the local election context the impugned articles were fair and reasonable comment on matters of public interest and did not, as reasonably read by Edmonton citizens, impute personal knowledge, participation or corrupt intention to the respondent; accordingly the defence of fair comment succeeded and the trial judgment dismissing the action was restored.

Citation
(1917) 55 SCR 454
Parties
Appellant (defendant): Bulletin Company Limited; Respondent (plaintiff): Rice Sheppard
Court
Supreme Court of Canada
Jurisdiction
Canada
Judgment Date
22 June 1917
Procedural Posture
Libel (defamation) / Appeal to Supreme Court of Canada From Appellate Division of the Supreme Court of Alberta
Outcome
Appeal allowed; judgment of trial judge restored; action dismissed
Legal Topics
Fair Comment, Public Interest, Personal Corruption, Innuendo, Responsibility of Public Officials
Source Language
English
Torts Defamation Media/press Law Municipal Law Fair Comment Public Interest Personal Corruption Innuendo +1 more

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Parties

Bulletin Company Limited

Appellant (defendant)

Rice Sheppard

Respondent (plaintiff)

Procedural Posture

Libel (defamation) / Appeal to Supreme Court of Canada From Appellate Division of the Supreme Court of Alberta

Legal Issues

  1. 1 Whether the newspaper articles constituted actionable libel or were protected as fair comment
  2. 2 Whether the articles imputed personal corruption or merely criticized a public administration
  3. 3 Whether comments on public officials in their official capacity can be treated as personal imputations

Ratio Decidendi

On the proved facts and in the local election context the impugned articles were fair and reasonable comment on matters of public interest and did not, as reasonably read by Edmonton citizens, impute personal knowledge, participation or corrupt intention to the respondent; accordingly the defence of fair comment succeeded and the trial judgment dismissing the action was restored.

Court Disposition

Appeal allowed; judgment of trial judge restored; action dismissed

Orders

  • Appeal allowed
  • Judgment of trial judge restored