Daniels v British Broadcasting Corporation (BBC) [2010] EWHC 3057 (QB) (24 November 2010)

Daniels v British Broadcasting Corporation (BBC) [2010] EWHC 3057 (QB) (24 November 2010)

The words complained of in the feedback schedule are not capable of bearing any defamatory meaning of the claimant. They amount to minor criticisms of work performance in a junior administrative role and do not meet the threshold of seriousness required for a defamation action. Even if they were capable of being defamatory, the publications were made on an occasion of qualified privilege, and there is no evidence of malice. The claims are totally without merit and constitute an abuse of process.

Citation
[2010] EWHC 3057 (QB)
Parties
Claimant: Dr Christopher Sydney Daniels; Defendant: British Broadcasting Corporation
Jurisdiction
England and Wales
Judgment Date
24 November 2010
Procedural Posture
Libel Actions (three Consolidated Claims) / Summary Judgment/strike Out Applications
Outcome
Claims struck out; summary judgment for defendants
Legal Topics
Libel, Qualified Privilege, Malice, Civil Restraint Orders, Multiplicity of Proceedings
Defamation Employment Law Libel Qualified Privilege Malice Civil Restraint Orders Multiplicity of Proceedings

Case Brief

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Parties

Dr Christopher Sydney Daniels

Claimant

British Broadcasting Corporation

Defendant

Procedural Posture

Libel Actions (three Consolidated Claims) / Summary Judgment/strike Out Applications

Legal Issues

  1. 1 Whether the words complained of are capable of bearing any defamatory meaning of the claimant
  2. 2 Whether the defence of qualified privilege applies to the publications
  3. 3 Whether there is any evidence of malice sufficient to defeat qualified privilege

Ratio Decidendi

The words complained of in the feedback schedule are not capable of bearing any defamatory meaning of the claimant. They amount to minor criticisms of work performance in a junior administrative role and do not meet the threshold of seriousness required for a defamation action. Even if they were capable of being defamatory, the publications were made on an occasion of qualified privilege, and there is no evidence of malice. The claims are totally without merit and constitute an abuse of process.

Court Disposition

Claims struck out; summary judgment for defendants

Orders

  • All three actions (against BBC, Ms Bird, Ms Heidari) are struck out
  • No extended civil restraint order made