Lachaux v Independent Print Ltd

Lachaux v Independent Print Ltd

The issues of serious harm, reference, and Jameel abuse are threshold conditions for defamation claims under the 2013 Act and can be determined as preliminary issues without recourse to pleaded Defence. Early determination aligns with the overriding objective and statutory ethos.

Parties
Claimant: Bruno Lachaux; Defendant: Independent Print Limited; Defendant: Evening Standard Limited; Defendant: AOL (UK) Limited
Jurisdiction
England and Wales
Judgment Date
01 April 2015
Procedural Posture
Defamation / Ruling on Applications for Trial of Preliminary Issues
Outcome
Applications for trial of preliminary issues granted.
Legal Topics
Serious Harm Threshold, Jameel Abuse, Preliminary Issues, Section 1 Defamation Act 2013
Defamation Civil Procedure Serious Harm Threshold Jameel Abuse Preliminary Issues Section 1 Defamation Act 2013

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Parties

Bruno Lachaux

Claimant

Independent Print Limited

Defendant

Evening Standard Limited

Defendant

AOL (UK) Limited

Defendant

Procedural Posture

Defamation / Ruling on Applications for Trial of Preliminary Issues

Legal Issues

  1. 1 Whether publication caused or is likely to cause serious harm to claimant's reputation under section 1 Defamation Act 2013
  2. 2 Whether pursuit of claim constitutes an abuse of process under Jameel principles
  3. 3 Whether claimant is identifiable from the publications

Ratio Decidendi

The issues of serious harm, reference, and Jameel abuse are threshold conditions for defamation claims under the 2013 Act and can be determined as preliminary issues without recourse to pleaded Defence. Early determination aligns with the overriding objective and statutory ethos.

Court Disposition

Applications for trial of preliminary issues granted.

Orders

  • Issues of serious harm, reference, and Jameel abuse to be tried as preliminary issues in all three actions.
  • Disputes as to meaning to be resolved at the same time.