Morgan v Associated Newspapers Ltd [2018] EWHC 1725 (QB) (06 July 2018)

Morgan v Associated Newspapers Ltd [2018] EWHC 1725 (QB) (06 July 2018)

The Article's meaning, as found by the Court, is sufficiently serious to give rise to a clear inference of serious reputational harm under s.1 Defamation Act 2013. The opinion denounces the Claimant in direct and forthright terms, is likely to provoke outrage, and is endorsed by authoritative sources and the publisher. The threshold of serious harm is met.

Citation
[2018] EWHC 1725
Parties
Claimant: Steve Morgan CBE; Defendant: Associated Newspapers Limited
Jurisdiction
England and Wales
Judgment Date
06 July 2018
Procedural Posture
Libel Claim / Preliminary Issues Hearing on Meaning, Fact/opinion, and Serious Harm Under S.1 Defamation Act 2013
Outcome
Application to amend Defence dismissed; Article found to convey a serious defamatory imputation causing serious harm under s.1 Defamation Act 2013.
Legal Topics
Libel, Serious Harm Threshold, Defamatory Meaning, Fact Vs Opinion, Honest Opinion Defence, Case Management in Defamation
Media Law Defamation Libel Serious Harm Threshold Defamatory Meaning Fact Vs Opinion Honest Opinion Defence Case Management in Defamation

Case Brief

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Parties

Steve Morgan CBE

Claimant

Associated Newspapers Limited

Defendant

Procedural Posture

Libel Claim / Preliminary Issues Hearing on Meaning, Fact/opinion, and Serious Harm Under S.1 Defamation Act 2013

Legal Issues

  1. 1 What is the natural and ordinary meaning of the Article?
  2. 2 Are the allegations in the Article statements of fact or opinion?
  3. 3 Does the Article convey a serious defamatory imputation under s.1(1) Defamation Act 2013?

Ratio Decidendi

The Article's meaning, as found by the Court, is sufficiently serious to give rise to a clear inference of serious reputational harm under s.1 Defamation Act 2013. The opinion denounces the Claimant in direct and forthright terms, is likely to provoke outrage, and is endorsed by authoritative sources and the publisher. The threshold of serious harm is met.

Court Disposition

Application to amend Defence dismissed; Article found to convey a serious defamatory imputation causing serious harm under s.1 Defamation Act 2013.

Orders

  • Defendant's application to amend Defence to withdraw admission of serious harm is dismissed.
  • Court finds Article conveys a serious defamatory imputation about the Claimant.