London Artists Ltd v Littler [1968] EWCA Civ 3 (10 December 1968)

London Artists Ltd v Littler [1968] EWCA Civ 3 (10 December 1968)

The defence of fair comment was not available because the statements complained of were assertions of fact, not comment, and there was no sufficient factual foundation for the alleged plot; therefore, the only issue for the jury was quantum of damages.

Source-derived case information.

Citation
[1968] EWCA Civ 3
Parties
Plaintiff: London Artists Ltd.; Plaintiff: The Grade Organisation Ltd.; Plaintiff: Associated Television Ltd.; Plaintiff: Mr. Lew Grade; Defendant/appellant: Mr. Emile Littler
Jurisdiction
England and Wales
Judgment Date
10 December 1968
Procedural Posture
Appeal / Appeal From Judgment of Mr. Justice Cantley and a Jury, London, Dated March 5, 1968
Outcome
Appeal dismissed
Legal Topics
Fair Comment, Libel, Public Interest, Pleading Requirements, Damages
Defamation Media Law Fair Comment Libel Public Interest Pleading Requirements Damages

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Parties

London Artists Ltd.

Plaintiff

The Grade Organisation Ltd.

Plaintiff

Associated Television Ltd.

Plaintiff

Mr. Lew Grade

Plaintiff

Mr. Emile Littler

Defendant/appellant

Procedural Posture

Appeal / Appeal From Judgment of Mr. Justice Cantley and a Jury, London, Dated March 5, 1968

Legal Issues

  1. 1 Whether the defence of fair comment was available to the defendant in a libel action concerning statements about an alleged plot to terminate a play's run.
  2. 2 Whether the matter was one of public interest.
  3. 3 Whether the statements were fact or comment, and whether there was a sufficient factual basis for the comment.

Ratio Decidendi

The defence of fair comment was not available because the statements complained of were assertions of fact, not comment, and there was no sufficient factual foundation for the alleged plot; therefore, the only issue for the jury was quantum of damages.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed with costs to all plaintiffs.
  • Leave to appeal to the House of Lords refused.