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 concern about his recent behaviour (Chase level 2), but not 'strong' grounds. The Second and Third Emails did not bear any defamatory meaning, as they were neutral notifications of departure without implication of misconduct.

Citation
[2021] EWHC 358 (QB)
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 on Meaning and Defamatory Tendency
Outcome
Preliminary issues determined: First Email bears a defamatory meaning at Chase level 2; Second and Third Emails do not bear a defamatory meaning.
Legal Topics
Libel, Defamatory Meaning, Chase Levels, Employment Termination, Sexual Misconduct Allegations
Defamation Media Law Libel Defamatory Meaning Chase Levels 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 on Meaning and Defamatory Tendency

Legal Issues

  1. 1 What is the natural and ordinary meaning of each of the three 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 concern about his recent behaviour (Chase level 2), but not 'strong' grounds. The Second and Third Emails did not bear any defamatory meaning, as they were neutral notifications of departure without implication of misconduct.

Court Disposition

Preliminary issues determined: First Email bears a defamatory meaning at Chase level 2; Second and Third Emails do not bear a defamatory meaning.

Orders

  • First Email: meaning determined as conveying reasonable grounds to suspect sexual misconduct and concern about behaviour.
  • Second Email: meaning determined as neutral notification of departure, not defamatory.