Riley v Murray [2020] EWHC 977 (QB) (24 April 2020)

Riley v Murray [2020] EWHC 977 (QB) (24 April 2020)

The Tweet's natural and ordinary meaning is that Jeremy Corbyn had been attacked at a mosque, the Claimant had publicly stated he deserved to be violently attacked, and by so doing, the Claimant showed herself to be dangerous and stupid, risking incitement of unlawful violence, so people should not engage with her. Paragraphs (1) and (2) are statements of fact, paragraph (3) is opinion. Paragraphs (2) and (3) are defamatory at common law. The Tweet is self-contained; external context is inadmissible. The innuendo meaning adds nothing material.

Citation
[2020] EWHC 977 (QB)
Parties
Claimant: Rachel Riley; Defendant: Laura Murray
Jurisdiction
England and Wales
Judgment Date
24 April 2020
Procedural Posture
Libel Action / Preliminary Issues Trial on Meaning, Fact/opinion, and Defamatory Tendency
Outcome
Preliminary issues determined: meaning found as set out by the Court; paragraphs (2) and (3) defamatory at common law; no material innuendo meaning.
Legal Topics
Libel, Social Media Publications, Natural and Ordinary Meaning, Defamatory Tendency, Fact Vs Opinion
Defamation Media Law Libel Social Media Publications Natural and Ordinary Meaning Defamatory Tendency Fact Vs Opinion

Case Brief

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Parties

Rachel Riley

Claimant

Laura Murray

Defendant

Procedural Posture

Libel Action / Preliminary Issues Trial on Meaning, Fact/opinion, and Defamatory Tendency

Legal Issues

  1. 1 What is the natural and ordinary meaning of the Tweet?
  2. 2 Does the Tweet convey a statement of fact or opinion, or both?
  3. 3 Does the meaning conveyed have a defamatory tendency at common law?

Ratio Decidendi

The Tweet's natural and ordinary meaning is that Jeremy Corbyn had been attacked at a mosque, the Claimant had publicly stated he deserved to be violently attacked, and by so doing, the Claimant showed herself to be dangerous and stupid, risking incitement of unlawful violence, so people should not engage with her. Paragraphs (1) and (2) are statements of fact, paragraph (3) is opinion. Paragraphs (2) and (3) are defamatory at common law. The Tweet is self-contained; external context is inadmissible. The innuendo meaning adds nothing material.

Court Disposition

Preliminary issues determined: meaning found as set out by the Court; paragraphs (2) and (3) defamatory at common law; no material innuendo meaning.

Orders

  • Defendant to serve Defence within 21 days after determination of preliminary issues.