Williams v MGM Ltd [2009] EWHC 3150 (QB) (02 December 2009)

Williams v MGM Ltd [2009] EWHC 3150 (QB) (02 December 2009)

The claim was struck out as an abuse of process because the claimant, having been convicted of murder and other serious offences, had no reputation capable of being damaged, and any damages or vindication would be minimal and disproportionate to the costs. The allegation of being a 'grass' was incapable of being defamatory as a matter of public policy. The claim was also brought out of time and there was no reason to disapply the limitation period.

Citation
[2009] EWHC 3150
Parties
Claimant: Peter Williams; Defendant: MGN Limited
Jurisdiction
England and Wales
Judgment Date
02 December 2009
Procedural Posture
Libel Action / Application to Strike Out Claim or for Summary Judgment
Outcome
Claim struck out
Legal Topics
Libel, Abuse of Process, Limitation Period, Defamatory Meaning, Summary Judgment
Defamation Civil Procedure Libel Abuse of Process Limitation Period Defamatory Meaning Summary Judgment

Case Brief

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Parties

Peter Williams

Claimant

MGN Limited

Defendant

Procedural Posture

Libel Action / Application to Strike Out Claim or for Summary Judgment

Legal Issues

  1. 1 Whether the article was capable of bearing a defamatory meaning against the claimant
  2. 2 Whether the claim constituted an abuse of process under the Jameel principle
  3. 3 Whether the claim was brought out of time and limitation should be disapplied

Ratio Decidendi

The claim was struck out as an abuse of process because the claimant, having been convicted of murder and other serious offences, had no reputation capable of being damaged, and any damages or vindication would be minimal and disproportionate to the costs. The allegation of being a 'grass' was incapable of being defamatory as a matter of public policy. The claim was also brought out of time and there was no reason to disapply the limitation period.

Court Disposition

Claim struck out

Orders

  • Claim struck out under CPR 3.4 for abuse of process
  • No order to disapply limitation period