Meade v Pugh & Anor [2004] EWHC 408 (QB) (05 March 2004)

Meade v Pugh & Anor [2004] EWHC 408 (QB) (05 March 2004)

There was no evidence that the defendants did not believe the truth of their feedback reports or that their dominant motive was malice; thus, the claim could not defeat qualified privilege and had no real prospect of success. The Master erred in law by not addressing the requirement for proof of lack of honest belief or dominant improper motive.

Citation
[2004] EWHC 408 (QB)
Parties
Claimant/respondent: Glenroy Terence Meade; Defendant/appellant: Katy Pugh; Defendant/appellant: Marie Hamilton
Jurisdiction
England and Wales
Judgment Date
05 March 2004
Procedural Posture
Libel Action (defamation) / Appeal From Master's Refusal to Strike Out Claim or Grant Summary Judgment
Outcome
Appeal allowed; summary judgment for defendants.
Legal Topics
Qualified Privilege, Malice in Defamation, Summary Judgment, Strike Out Applications, Appeals Procedure
Defamation Civil Procedure Qualified Privilege Malice in Defamation Summary Judgment Strike Out Applications Appeals Procedure

Case Brief

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Parties

Glenroy Terence Meade

Claimant/respondent

Katy Pugh

Defendant/appellant

Marie Hamilton

Defendant/appellant

Procedural Posture

Libel Action (defamation) / Appeal From Master's Refusal to Strike Out Claim or Grant Summary Judgment

Legal Issues

  1. 1 Whether the defendants' feedback reports were protected by qualified privilege
  2. 2 Whether the claimant had a real prospect of defeating qualified privilege by proving malice
  3. 3 Whether the claim should be struck out or summary judgment granted for the defendants

Ratio Decidendi

There was no evidence that the defendants did not believe the truth of their feedback reports or that their dominant motive was malice; thus, the claim could not defeat qualified privilege and had no real prospect of success. The Master erred in law by not addressing the requirement for proof of lack of honest belief or dominant improper motive.

Court Disposition

Appeal allowed; summary judgment for defendants.

Orders

  • Claim struck out and summary judgment entered for the defendants.
  • Permission to amend particulars of claim refused.