Courtney v Ronksley [2024] EWHC 572 (KB) (13 March 2024)

Courtney v Ronksley [2024] EWHC 572 (KB) (13 March 2024)

The Claimant failed to provide evidence, or a reasonable basis for expecting evidence at trial, that any publishee thought seriously the worse of him as a result of the letter complained of. The evidence from publishees was that the letter had no adverse impact on their opinion of the Claimant. The claim did not meet the statutory threshold of serious harm under s.1(1) Defamation Act 2013 and had no real prospect of success. There was no other compelling reason for a trial.

Citation
[2024] EWHC 572 (KB)
Parties
Claimant: Mr Keith Courtney; Defendant: Mr Richard Ronksley
Jurisdiction
England and Wales
Judgment Date
13 March 2024
Procedural Posture
Defamation (libel) / Summary Judgment Application by Defendant
Outcome
Claim dismissed by summary judgment.
Legal Topics
Serious Harm Threshold, Summary Judgment, Strike Out, Publication to Limited Class, Reputational Harm, Defamation Act 2013 S.1(1)
Defamation Media Law Serious Harm Threshold Summary Judgment Strike Out Publication to Limited Class Reputational Harm Defamation Act 2013 S.1(1)

Case Brief

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Parties

Mr Keith Courtney

Claimant

Mr Richard Ronksley

Defendant

Procedural Posture

Defamation (libel) / Summary Judgment Application by Defendant

Legal Issues

  1. 1 Whether the publication of the statement complained of caused or is likely to cause serious harm to the Claimant's reputation under s.1(1) Defamation Act 2013
  2. 2 Whether the claim should be summarily dismissed for lack of real prospect of success
  3. 3 Whether parts of the claim should be struck out for disclosing no reasonable grounds or being abusive

Ratio Decidendi

The Claimant failed to provide evidence, or a reasonable basis for expecting evidence at trial, that any publishee thought seriously the worse of him as a result of the letter complained of. The evidence from publishees was that the letter had no adverse impact on their opinion of the Claimant. The claim did not meet the statutory threshold of serious harm under s.1(1) Defamation Act 2013 and had no real prospect of success. There was no other compelling reason for a trial.

Court Disposition

Claim dismissed by summary judgment.

Orders

  • Summary judgment granted in favour of the Defendant.
  • Claim dismissed in its entirety.