Ogunkami v Chia [2026] EWCA Civ 588 (13 May 2026)

Ogunkami v Chia [2026] EWCA Civ 588 (13 May 2026)

The claimant failed to plead and prove the necessary ingredients for damages for foreign publication. The judge was entitled to limit damages to harm within England and Wales. The late application to amend pleadings to claim global harm was properly refused. The appeal is dismissed.

Citation
[2026] EWCA Civ 588
Parties
Claimant/appellant: Idowu Ogunkami; Defendant/respondent: Cynthia Chia
Jurisdiction
England and Wales
Judgment Date
13 May 2026
Procedural Posture
Appeal (civil) / Appeal Against Assessment of Damages Following Default Judgment
Outcome
Appeal dismissed
Legal Topics
Assessment of Damages, Jurisdiction, Foreign Publication, Double Actionability, Default Judgment, Amendment of Pleadings
Defamation Harassment Media Law Civil Procedure Assessment of Damages Jurisdiction Foreign Publication Double Actionability +2 more

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Parties

Idowu Ogunkami

Claimant/appellant

Cynthia Chia

Defendant/respondent

Procedural Posture

Appeal (civil) / Appeal Against Assessment of Damages Following Default Judgment

Legal Issues

  1. 1 Whether damages for libel should include harm caused by publication abroad or be limited to harm within England and Wales
  2. 2 Whether the claimant was entitled to amend his pleadings to claim global harm after default judgment

Ratio Decidendi

The claimant failed to plead and prove the necessary ingredients for damages for foreign publication. The judge was entitled to limit damages to harm within England and Wales. The late application to amend pleadings to claim global harm was properly refused. The appeal is dismissed.

Court Disposition

Appeal dismissed

Orders

  • Award of £25,000 in damages for both harassment and libel upheld
  • Injunctive relief against the respondent maintained