Angel v Stainton & Anor [2006] EWHC 637 (QB) (28 March 2006)

Angel v Stainton & Anor [2006] EWHC 637 (QB) (28 March 2006)

Given the gravity of the libel, the limited but targeted publication, and the significant distress caused, the starting figure for compensation is £40,000. However, due to the defendants' delayed and grudging offer of amends, and aggravating conduct, only a 40% reduction is appropriate, resulting in an award of £24,000.

Citation
[2006] EWHC 637
Parties
Claimant: Norman Angel; Defendant: Adrian Stainton; Defendant: Repaircraft PLC
Jurisdiction
England and Wales
Judgment Date
28 March 2006
Procedural Posture
Libel Action (defamation) / Assessment of Compensation Under Offer of Amends Procedure (defamation Act 1996, S.3(5))
Outcome
Claimant awarded compensation for libel under the offer of amends procedure.
Legal Topics
Libel, Offer of Amends, Damages Assessment, Aggravated Damages, Mitigation of Damages
Defamation Media Law Tort Libel Offer of Amends Damages Assessment Aggravated Damages Mitigation of Damages

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Parties

Norman Angel

Claimant

Adrian Stainton

Defendant

Repaircraft PLC

Defendant

Procedural Posture

Libel Action (defamation) / Assessment of Compensation Under Offer of Amends Procedure (defamation Act 1996, S.3(5))

Legal Issues

  1. 1 What is the appropriate amount of compensation for libel under the offer of amends procedure?
  2. 2 To what extent do aggravating and mitigating factors affect the quantum of damages in this context?

Ratio Decidendi

Given the gravity of the libel, the limited but targeted publication, and the significant distress caused, the starting figure for compensation is £40,000. However, due to the defendants' delayed and grudging offer of amends, and aggravating conduct, only a 40% reduction is appropriate, resulting in an award of £24,000.

Court Disposition

Claimant awarded compensation for libel under the offer of amends procedure.

Orders

  • Defendants to pay £24,000 to the claimant as compensation.