Simon Blake & Anor v Laurence Fox
The gravity of the libel, its mass publication, the claimants' particular vulnerability, and the absence of unequivocal apology or retraction justified a substantial compensatory award of £90,000 each. The risk of repetition by the defendant, evidenced by his conduct and lack of undertakings, made an injunction necessary and proportionate. Compulsory publication of a summary was not necessary or proportionate given the wide public knowledge of the outcome and risk of further humiliation.
- Parties
- Claimant: Mr Simon Blake; Claimant: Mr Colin Seymour; Defendant: Mr Laurence Fox
- Jurisdiction
- England and Wales
- Judgment Date
- 25 April 2024
- Procedural Posture
- Defamation (libel) Claim / Remedies Judgment Following Liability Judgment
- Outcome
- Judgment for the claimants on remedies; damages and injunction granted; publication order refused.
- Legal Topics
- Libel Damages, Injunctive Relief, Publication of Judgment Summary, Vindication of Reputation
Case Brief
Summary, issues, holding and outcome
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Parties
Mr Simon Blake
Claimant
Mr Colin Seymour
Claimant
Mr Laurence Fox
Defendant
Procedural Posture
Defamation (libel) Claim / Remedies Judgment Following Liability Judgment
Legal Issues
- 1 Appropriate quantum of damages for libel
- 2 Whether to grant injunctive relief restraining repetition of libel
- 3 Whether to order publication of a summary of the judgment
Ratio Decidendi
The gravity of the libel, its mass publication, the claimants' particular vulnerability, and the absence of unequivocal apology or retraction justified a substantial compensatory award of £90,000 each. The risk of repetition by the defendant, evidenced by his conduct and lack of undertakings, made an injunction necessary and proportionate. Compulsory publication of a summary was not necessary or proportionate given the wide public knowledge of the outcome and risk of further humiliation.
Court Disposition
Judgment for the claimants on remedies; damages and injunction granted; publication order refused.
Orders
- Defendant to pay £90,000 to each claimant as compensatory damages.
- Defendant restrained by injunction from repeating the same or similar allegations about the claimants.
Full Case Text
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