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, due to his serious criminal convictions, had no reputation capable of being protected and any damages would be minimal and disproportionate to the costs. Additionally, the allegation of being a police informer was not capable of being defamatory as a matter of public policy.

Citation
[2009] EWHC 3150 (QB)
Parties
Claimant: Peter Williams; Defendant: MGN Limited
Jurisdiction
England and Wales
Judgment Date
02 December 2009
Procedural Posture
Libel Action / Application to Strike Out or for Summary Judgment
Outcome
Claim struck out
Legal Topics
Libel, Abuse of Process, Limitation Periods, Defamatory Meaning, Summary Judgment
Defamation Civil Procedure Libel Abuse of Process Limitation Periods 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 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, due to his serious criminal convictions, had no reputation capable of being protected and any damages would be minimal and disproportionate to the costs. Additionally, the allegation of being a police informer was not capable of being defamatory as a matter of public policy.

Court Disposition

Claim struck out

Orders

  • Claim struck out under CPR 3.4 for abuse of process
  • No disapplication of limitation period