Glenn v Kline [2021] EWHC 468 (QB) (05 March 2021)
The Defendant's persistent, serious, and unsubstantiated campaign of libel and harassment against the Claimant, including repeated publication of grave allegations without evidence, justified substantial damages, aggravated damages, and injunctive relief. The Claimant was entitled to amend the claim to increase damages sought, and to an order for publication of a summary of the judgment. The Defendant's non-engagement and failure to defend or comply with court orders aggravated the harm and justified the remedies granted.
- Citation
- [2021] EWHC 468 (QB)
- Parties
- Claimant: Martin Glenn; Defendant: Craig Kline
- Jurisdiction
- England and Wales
- Judgment Date
- 05 March 2021
- Procedural Posture
- Libel and Harassment Claim / Remedies Hearing Following Default Judgment
- Outcome
- Claim allowed. Damages awarded. Amendment of claim permitted. Order for publication of summary judgment. Costs awarded.
- Legal Topics
- Libel, Online Harassment, Default Judgment, Damages Assessment, Freedom of Expression, Amendment of Claim, Costs
Case Brief
Summary, issues, holding and outcome
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Parties
Martin Glenn
Claimant
Craig Kline
Defendant
Procedural Posture
Libel and Harassment Claim / Remedies Hearing Following Default Judgment
Legal Issues
- 1 Appropriate measure of damages for libel and harassment
- 2 Whether to permit amendment of claim to increase damages sought
- 3 Whether to order publication of summary of judgment under s12 Defamation Act 2013
Ratio Decidendi
The Defendant's persistent, serious, and unsubstantiated campaign of libel and harassment against the Claimant, including repeated publication of grave allegations without evidence, justified substantial damages, aggravated damages, and injunctive relief. The Claimant was entitled to amend the claim to increase damages sought, and to an order for publication of a summary of the judgment. The Defendant's non-engagement and failure to defend or comply with court orders aggravated the harm and justified the remedies granted.
Court Disposition
Claim allowed. Damages awarded. Amendment of claim permitted. Order for publication of summary judgment. Costs awarded.
Orders
- Permission granted to amend claim to increase damages sought to £100,000, conditional on payment of additional court fee.
- General damages for harassment (pre-May 2019 publications) awarded at £25,000.
Full Case Text
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