Cruddas v Calvert & Ors

Cruddas v Calvert & Ors

The articles do not carry the imputation that Mr Cruddas was criminally corrupt; the natural and ordinary meaning is one of impropriety, not criminality. The defence of justification should not be struck out, and the case should proceed to trial on the lesser meaning. For malicious falsehood, the imputation of criminal corruption is a reasonably available meaning, but whether it was false or malicious must await trial.

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
Civil Appeal / Appeal From High Court Preliminary Ruling on Meaning and Strike Out of Defence
Outcome
Appeal allowed in part
Legal Topics
Libel, Malicious Falsehood, Justification, Meaning of Defamatory Statements

Case Brief

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Parties

Peter Cruddas

Respondent

Jonathan Calvert

Appellant

Heidi Blake

Appellant

Times Newspapers Limited

Appellant

Procedural Posture

Civil Appeal / Appeal From High Court Preliminary Ruling on Meaning and Strike Out of Defence

  1. 1 What is the natural and ordinary meaning of the articles for libel purposes?
  2. 2 Does the meaning impute criminal corruption or merely impropriety?
  3. 3 Should the defence of justification be struck out?

Ratio Decidendi

The articles do not carry the imputation that Mr Cruddas was criminally corrupt; the natural and ordinary meaning is one of impropriety, not criminality. The defence of justification should not be struck out, and the case should proceed to trial on the lesser meaning. For malicious falsehood, the imputation of criminal corruption is a reasonably available meaning, but whether it was false or malicious must await trial.

Court Disposition

Appeal allowed in part

Orders

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