Cruddas v Calvert & Ors

Cruddas v Calvert & Ors

The Court of Appeal held that the first meaning (that the claimant offered access and influence in return for donations, which was inappropriate, unacceptable and wrong) was substantially true, so the defendants were not liable for libel or malicious falsehood in respect of that meaning. However, the second and third meanings (that the claimant countenanced or facilitated illegal foreign donations) were not justified, and the defendants were liable for libel and malicious falsehood in respect of those meanings. The damages were reduced to reflect the partial success of the defendants, and the injunction was limited to the proven libels.

Parties
Claimant/respondent: Peter Cruddas; Defendant/appellant: Jonathan Calvert; Defendant/appellant: Heidi Blake; Defendant/appellant: Times Newspapers Ltd
Jurisdiction
England and Wales
Judgment Date
17 March 2015
Procedural Posture
Civil Appeal / Appeal From High Court Judgment
Outcome
Appeal allowed in part; damages and injunction modified
Legal Topics
Libel, Malicious Falsehood, Political Donations, Journalistic Privilege, Damages, Injunctions
Defamation Media Law Tort Law Libel Malicious Falsehood Political Donations Journalistic Privilege Damages +1 more

Case Brief

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Parties

Peter Cruddas

Claimant/respondent

Jonathan Calvert

Defendant/appellant

Heidi Blake

Defendant/appellant

Times Newspapers Ltd

Defendant/appellant

Procedural Posture

Civil Appeal / Appeal From High Court Judgment

Legal Issues

  1. 1 Whether the published articles were defamatory and/or malicious falsehoods against the claimant
  2. 2 Whether the meanings attributed to the articles were true or false
  3. 3 Whether the defendants acted with malice in publishing the articles

Ratio Decidendi

The Court of Appeal held that the first meaning (that the claimant offered access and influence in return for donations, which was inappropriate, unacceptable and wrong) was substantially true, so the defendants were not liable for libel or malicious falsehood in respect of that meaning. However, the second and third meanings (that the claimant countenanced or facilitated illegal foreign donations) were not justified, and the defendants were liable for libel and malicious falsehood in respect of those meanings. The damages were reduced to reflect the partial success of the defendants, and the injunction was limited to the proven libels.

Court Disposition

Appeal allowed in part; damages and injunction modified

Orders

  • Damages reduced to £50,000 (general damages £43,000, aggravated damages £7,000)
  • Injunction limited to restraining repetition of the second and third meanings only