Cruddas v Calvert & Ors [2013] EWCA Civ 748 (21 June 2013)

Cruddas v Calvert & Ors [2013] EWCA Civ 748 (21 June 2013)

The articles did not impute criminal corruption to Mr Cruddas; the natural and ordinary meaning was not that he committed a criminal offence but that he engaged in inappropriate and wrong conduct. The defence of justification should not have been struck out as the defendants are entitled to justify the lesser defamatory meaning. The pleaded meanings for malicious falsehood are available and must be determined at trial.

Citation
[2013] EWCA Civ 748
Parties
Respondent: Peter Cruddas; Appellant: Jonathan Calvert; Appellant: Heidi Blake; Appellant: Times Newspapers Limited
Jurisdiction
England and Wales
Judgment Date
21 June 2013
Procedural Posture
Appeal / Court of Appeal Judgment on Appeal From High Court
Outcome
Appeal allowed in part
Legal Topics
Libel, Malicious Falsehood, Meaning of Defamatory Statements, Justification Defence, Electoral Law
Media Law Defamation Tort Libel Malicious Falsehood Meaning of Defamatory Statements Justification Defence Electoral Law

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Parties

Peter Cruddas

Respondent

Jonathan Calvert

Appellant

Heidi Blake

Appellant

Times Newspapers Limited

Appellant

Procedural Posture

Appeal / Court of Appeal Judgment on Appeal From High Court

Legal Issues

  1. 1 What is the natural and ordinary meaning of the articles for libel and malicious falsehood claims?
  2. 2 Does the meaning of the articles impute criminal corruption to Mr Cruddas?
  3. 3 Should the defence of justification be struck out?

Ratio Decidendi

The articles did not impute criminal corruption to Mr Cruddas; the natural and ordinary meaning was not that he committed a criminal offence but that he engaged in inappropriate and wrong conduct. The defence of justification should not have been struck out as the defendants are entitled to justify the lesser defamatory meaning. The pleaded meanings for malicious falsehood are available and must be determined at trial.

Court Disposition

Appeal allowed in part

Orders

  • Declaration that the articles do not allege criminal corruption for libel purposes
  • Orders striking out paragraphs 7 and 8 of the amended defence set aside