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

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

The appropriate compensation for the libel, considering the gravity of the allegation and limited publication, is £40,000, reduced by 40% to £24,000 due to the defendants' delayed and grudging offer of amends and aggravating conduct, but with some mitigation for eventually following the statutory procedure.

Citation
[2006] EWHC 637 (QB)
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 Following Offer of Amends Under Defamation Act 1996
Outcome
Claim allowed; compensation awarded to claimant.
Legal Topics
Libel, Offer of Amends, Damages Assessment, Aggravated Damages
Defamation Media Law Tort Libel Offer of Amends Damages Assessment Aggravated Damages

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Parties

Norman Angel

Claimant

Adrian Stainton

Defendant

Repaircraft PLC

Defendant

Procedural Posture

Libel Action (defamation) / Assessment of Compensation Following Offer of Amends Under Defamation Act 1996

Legal Issues

  1. 1 What is the appropriate amount of compensation for the libel under the offer of amends procedure?
  2. 2 To what extent should the compensation be mitigated by the defendants' conduct, including the timing and nature of the offer of amends and subsequent correspondence?

Ratio Decidendi

The appropriate compensation for the libel, considering the gravity of the allegation and limited publication, is £40,000, reduced by 40% to £24,000 due to the defendants' delayed and grudging offer of amends and aggravating conduct, but with some mitigation for eventually following the statutory procedure.

Court Disposition

Claim allowed; compensation awarded to claimant.

Orders

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