Hodges v Naish (Rev1) [2021] EWHC 1805 (QB) (01 July 2021)

Hodges v Naish (Rev1) [2021] EWHC 1805 (QB) (01 July 2021)

The defendant published defamatory statements to Conor Kennedy, John McCullough, and Kevin Goble, imputing criminal conduct and professional misconduct, which are actionable as slander per se without proof of special damage. The words were statements of fact, not opinion, and caused serious harm to the claimant's reputation. The claim regarding publication to Elaine Walker failed due to lack of evidence.

Citation
[2021] EWHC 1805
Parties
Claimant: Jamie Hodges; Defendant: Christopher Naish
Jurisdiction
England and Wales
Judgment Date
01 July 2021
Procedural Posture
Slander Action / Trial of Preliminary Issues
Outcome
Claim partially succeeds
Legal Topics
Slander, Serious Harm, Defamatory Meaning, Actionability Per Se, Limitation
Defamation Media Law Slander Serious Harm Defamatory Meaning Actionability Per Se Limitation

Case Brief

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Parties

Jamie Hodges

Claimant

Christopher Naish

Defendant

Procedural Posture

Slander Action / Trial of Preliminary Issues

Legal Issues

  1. 1 Whether the defendant published defamatory words to specified individuals
  2. 2 Whether the words were statements of fact or opinion
  3. 3 Whether the words were actionable as slander per se

Ratio Decidendi

The defendant published defamatory statements to Conor Kennedy, John McCullough, and Kevin Goble, imputing criminal conduct and professional misconduct, which are actionable as slander per se without proof of special damage. The words were statements of fact, not opinion, and caused serious harm to the claimant's reputation. The claim regarding publication to Elaine Walker failed due to lack of evidence.

Court Disposition

Claim partially succeeds

Orders

  • Claim for slander in respect of publications to Conor Kennedy, John McCullough, and Kevin Goble succeeds
  • Claim for publication to Elaine Walker dismissed