Angel v Stainton & Anor

Angel v Stainton & Anor

The appropriate compensation for the libel, considering the gravity of the allegation and limited publication, was £40,000. However, due to the defendants' delayed and grudging offer of amends, and aggravating conduct, only a 40% reduction was justified, resulting in an award of £24,000.

Parties
Claimant: Norman Angel; Defendant: Adrian Stainton; Defendant: Repaircraft PLC
Jurisdiction
England and Wales
Judgment Date
28 March 2006
Procedural Posture
Defamation (libel) / Assessment of Compensation Following Offer of Amends Under Defamation Act 1996
Outcome
Judgment for the claimant; compensation awarded.
Legal Topics
Libel, Offer of Amends, Damages Assessment, Aggravation and Mitigation of Damages

Case Brief

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Parties

Norman Angel

Claimant

Adrian Stainton

Defendant

Repaircraft PLC

Defendant

Procedural Posture

Defamation (libel) / Assessment of Compensation Following Offer of Amends Under Defamation Act 1996

  1. 1 What is the appropriate amount of compensation for libel following an offer of amends under the Defamation Act 1996?
  2. 2 To what extent should the compensation be reduced due to the offer of amends and any mitigating/aggravating factors?

Ratio Decidendi

The appropriate compensation for the libel, considering the gravity of the allegation and limited publication, was £40,000. However, due to the defendants' delayed and grudging offer of amends, and aggravating conduct, only a 40% reduction was justified, resulting in an award of £24,000.

Court Disposition

Judgment for the claimant; compensation awarded.

Orders

  • The defendants shall pay the claimant £24,000 by way of compensation.