Riley v Murray [2022] EWCA Civ 1146 (11 August 2022)

Riley v Murray [2022] EWCA Civ 1146 (11 August 2022)

The defendant's tweet was not substantially true as it misrepresented the ambiguity of the claimant's Good Advice Tweet, presenting an unequivocal defamatory statement. The honest opinion defence failed because the opinion was expressly premised on a false factual assertion. The public interest defence failed as the defendant's belief was not reasonable due to misrepresentation and omission of the original tweet's context.

Citation
[2022] EWCA Civ 1146
Parties
Claimant/respondent: Rachel Riley; Defendant/appellant: Laura Murray
Jurisdiction
England and Wales
Judgment Date
11 August 2022
Procedural Posture
Appeal From High Court (queen’s Bench Division, Media and Communications List) / Court of Appeal Judgment
Outcome
Appeal dismissed; judgment for the claimant upheld.
Legal Topics
Libel, Defamation Act 2013, Truth Defence, Honest Opinion Defence, Public Interest Defence
Defamation Media Law Tort Libel Defamation Act 2013 Truth Defence Honest Opinion Defence Public Interest Defence

Case Brief

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Parties

Rachel Riley

Claimant/respondent

Laura Murray

Defendant/appellant

Procedural Posture

Appeal From High Court (queen’s Bench Division, Media and Communications List) / Court of Appeal Judgment

Legal Issues

  1. 1 Whether the tweet by Laura Murray was defamatory of Rachel Riley
  2. 2 Application of statutory defences under Defamation Act 2013: truth, honest opinion, public interest
  3. 3 Interpretation of ambiguous social media statements in libel context

Ratio Decidendi

The defendant's tweet was not substantially true as it misrepresented the ambiguity of the claimant's Good Advice Tweet, presenting an unequivocal defamatory statement. The honest opinion defence failed because the opinion was expressly premised on a false factual assertion. The public interest defence failed as the defendant's belief was not reasonable due to misrepresentation and omission of the original tweet's context.

Court Disposition

Appeal dismissed; judgment for the claimant upheld.

Orders

  • Damages of £10,000 awarded to Rachel Riley
  • No change to damages assessment