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

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

The defendant did publish defamatory words to Conor Kennedy, John McCullough, and Kevin Goble, accusing the claimant of grooming young girls and having STDs, which were statements of fact, defamatory at common law, and likely to cause serious harm. The claim regarding publication to Elaine Walker failed due to insufficient evidence. The words published were actionable as slander per se without proof of special damage.

Citation
[2021] EWHC 1805 (QB)
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 Period
Defamation Media Law Slander Serious Harm Defamatory Meaning Actionability Per Se Limitation Period

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 4 Party arguments 2
Sign in to unlock

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 defamatory at common law

Ratio Decidendi

The defendant did publish defamatory words to Conor Kennedy, John McCullough, and Kevin Goble, accusing the claimant of grooming young girls and having STDs, which were statements of fact, defamatory at common law, and likely to cause serious harm. The claim regarding publication to Elaine Walker failed due to insufficient evidence. The words published were actionable as slander per se without proof of special damage.

Court Disposition

Claim partially succeeds

Orders

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