Ijaz v Manan [2021] EWHC 3683 (QB) (07 December 2021)

Ijaz v Manan [2021] EWHC 3683 (QB) (07 December 2021)

The court determined the natural and ordinary meanings of the five publications, applying the Chase levels of meaning. The April and May texts, sent only to the claimant's father who did not believe the allegations, did not constitute a real and substantial tort under the Jameel jurisdiction and were struck out. The remaining publications were found to bear defamatory meanings at various Chase levels.

Citation
[2021] EWHC 3683
Parties
Claimant: Hamza Ijaz; Defendant: Ghafoor Manan
Jurisdiction
England and Wales
Judgment Date
07 December 2021
Procedural Posture
Civil Defamation (libel) / Preliminary Issues Trial on Meaning and Jameel Jurisdiction
Outcome
Libel claims based on the April and May texts struck out under Jameel jurisdiction; meanings of all five publications determined.
Legal Topics
Libel, Meaning of Defamatory Statements, Jameel Jurisdiction, Threshold of Seriousness, Chase Levels of Meaning
Defamation Tort Libel Meaning of Defamatory Statements Jameel Jurisdiction Threshold of Seriousness Chase Levels of Meaning

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Parties

Hamza Ijaz

Claimant

Ghafoor Manan

Defendant

Procedural Posture

Civil Defamation (libel) / Preliminary Issues Trial on Meaning and Jameel Jurisdiction

Legal Issues

  1. 1 What are the natural and ordinary meanings of the five pleaded publications?
  2. 2 Do the April and May texts constitute a serious and substantial tort under the Jameel jurisdiction?

Ratio Decidendi

The court determined the natural and ordinary meanings of the five publications, applying the Chase levels of meaning. The April and May texts, sent only to the claimant's father who did not believe the allegations, did not constitute a real and substantial tort under the Jameel jurisdiction and were struck out. The remaining publications were found to bear defamatory meanings at various Chase levels.

Court Disposition

Libel claims based on the April and May texts struck out under Jameel jurisdiction; meanings of all five publications determined.

Orders

  • April and May text claims struck out as not constituting a real and substantial tort.
  • Sixth publication removed from the defamation claims as not relied upon.