Sellers v Secretary of State for Foreign, Commonwealth And Development Affairs & Anor [2021] EWHC 358 (QB) (19 February 2021)

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

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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

  1. 1 What is the natural and ordinary meaning of the First, Second, and Third Emails?
  2. 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.