Lachaux v Independent Print Ltd & Anor[2021] EWHC 1797 (QB) (01 July 2021)

Lachaux v Independent Print Ltd & Anor[2021] EWHC 1797 (QB) (01 July 2021)

The court found that the articles published by the defendants contained grave allegations that were widely disseminated and caused serious harm to the claimant's reputation. The public interest defence under s.4 Defamation Act 2013 was not made out because the defendants failed to demonstrate that they reasonably believed publication was in the public interest, particularly as they did not seek the claimant's response or comply with journalistic standards. The claimant was entitled to damages, including aggravated damages, and injunctive relief.

Citation
[2021] EWHC 1797 (QB)
Parties
Claimant: Bruno Lachaux; First Defendant: Independent Print Limited; Second Defendant: Evening Standard Limited
Jurisdiction
England and Wales
Judgment Date
01 July 2021
Procedural Posture
Libel/defamation / Trial Judgment After Supreme Court Appeals on Preliminary Issues
Outcome
Claim allowed
Legal Topics
Libel, Serious Harm, Public Interest Defence, Journalistic Standards, Damages
Media Law Defamation Tort Law Libel Serious Harm Public Interest Defence Journalistic Standards Damages

Case Brief

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Parties

Bruno Lachaux

Claimant

Independent Print Limited

First Defendant

Evening Standard Limited

Second Defendant

Procedural Posture

Libel/defamation / Trial Judgment After Supreme Court Appeals on Preliminary Issues

Legal Issues

  1. 1 Whether the publications caused serious harm to the claimant's reputation under s.1 Defamation Act 2013
  2. 2 Whether the public interest defence under s.4 Defamation Act 2013 is made out
  3. 3 Whether the defendants complied with journalistic standards and codes of practice

Ratio Decidendi

The court found that the articles published by the defendants contained grave allegations that were widely disseminated and caused serious harm to the claimant's reputation. The public interest defence under s.4 Defamation Act 2013 was not made out because the defendants failed to demonstrate that they reasonably believed publication was in the public interest, particularly as they did not seek the claimant's response or comply with journalistic standards. The claimant was entitled to damages, including aggravated damages, and injunctive relief.

Court Disposition

Claim allowed

Orders

  • Defendants to pay general and aggravated damages to the claimant
  • Defendants restrained by injunction from repeating the allegations