Crow v Johnson [2012] EWHC 1982 (QB) (16 July 2012)

Crow v Johnson [2012] EWHC 1982 (QB) (16 July 2012)

The words complained of are not capable of being defamatory of Mr Crow within the latitude permitted by law in the context of an election; the claim discloses no reasonable grounds and must be struck out.

Citation
[2012] EWHC 1982
Parties
Claimant: Robert Crow; Defendant: Boris Johnson
Jurisdiction
England and Wales
Judgment Date
16 July 2012
Procedural Posture
Libel Action / Application to Strike Out Claim and for Permission to Amend Claim Form
Outcome
Claim struck out
Legal Topics
Defamatory Meaning, Freedom of Expression, Political Speech, Strike Out Application
Defamation Media Law Election Law Defamatory Meaning Freedom of Expression Political Speech Strike Out Application

Case Brief

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Parties

Robert Crow

Claimant

Boris Johnson

Defendant

Procedural Posture

Libel Action / Application to Strike Out Claim and for Permission to Amend Claim Form

Legal Issues

  1. 1 Are the words complained of capable of bearing a defamatory meaning against Mr Crow?
  2. 2 Are the words capable of being understood as referring to Mr Crow?
  3. 3 Does the context of political speech during an election affect the defamatory meaning?

Ratio Decidendi

The words complained of are not capable of being defamatory of Mr Crow within the latitude permitted by law in the context of an election; the claim discloses no reasonable grounds and must be struck out.

Court Disposition

Claim struck out

Orders

  • Action struck out under CPR r.3.4(2)(a)
  • Permission to amend claim form refused as claim discloses no reasonable grounds