Sellers v Secretary of State for Foreign, Commonwealth And Development Affairs & Anor [2021] EWHC 358 (QB) (19 February 2021)
The First Email conveyed that there are reasonable grounds to suspect the claimant of sexual misconduct and erratic behaviour, but not strong grounds; the Second and Third Emails were neutral announcements of departure and did not bear any defamatory meaning at common law.
- Citation
- [2021] EWHC 358
- Parties
- Claimant: Paul Anthony Sellers; First Defendant: Secretary of State for Foreign, Commonwealth and Development Affairs; Second Defendant: The British Council
- Jurisdiction
- England and Wales
- Judgment Date
- 19 February 2021
- Procedural Posture
- Libel Claim (defamation) / Preliminary Issues Judgment on Meaning and Defamatory Tendency
- Outcome
- Preliminary issues determined; only the First Email found to bear a defamatory meaning; Second and Third Emails not defamatory at common law.
- Legal Topics
- Libel, Defamatory Meaning, Defamatory Tendency, Employment Termination, Sexual Misconduct Allegations
Case Brief
Summary, issues, holding and outcome
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Parties
Paul Anthony Sellers
Claimant
Secretary of State for Foreign, Commonwealth and Development Affairs
First Defendant
The British Council
Second Defendant
Procedural Posture
Libel Claim (defamation) / Preliminary Issues Judgment on Meaning and Defamatory Tendency
Legal Issues
- 1 What is the natural and ordinary meaning of the First, Second, and Third Emails?
- 2 Do any of the emails bear a defamatory meaning at common law?
Ratio Decidendi
The First Email conveyed that there are reasonable grounds to suspect the claimant of sexual misconduct and erratic behaviour, but not strong grounds; the Second and Third Emails were neutral announcements of departure and did not bear any defamatory meaning at common law.
Court Disposition
Preliminary issues determined; only the First Email found to bear a defamatory meaning; Second and Third Emails not defamatory at common law.
Orders
- The natural and ordinary meaning of the First Email is as set out in the judgment and is defamatory.
- The Second and Third Emails do not bear a defamatory meaning at common law.
Full Case Text
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