McKenna v MGN Ltd [2006] EWHC 1996 (QB) (28 July 2006)

McKenna v MGN Ltd [2006] EWHC 1996 (QB) (28 July 2006)

The article published by MGN Ltd was defamatory of Paul McKenna in alleging that he fraudulently claimed a bogus PhD while knowing it was bogus. The defendant failed to prove to the civil standard that McKenna knew his degree was bogus or that he acted dishonestly. The evidence showed McKenna acted in good faith, submitted work, and was unaware of the university's lack of accreditation until after the fact. The defence of justification failed. Damages were awarded for injury to reputation and hurt feelings.

Citation
[2006] EWHC 1996
Parties
Defendant: Paul McKenna; Claimant: MGN Ltd
Jurisdiction
England and Wales
Judgment Date
28 July 2006
Procedural Posture
Defamation / High Court Trial Judgment
Outcome
Claimant succeeds. Judgment for Paul McKenna.
Legal Topics
Libel, Justification Defence, Meaning of Defamatory Statements, Damages for Injury to Reputation
Media Law Defamation Libel Justification Defence Meaning of Defamatory Statements Damages for Injury to Reputation

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 3 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

Paul McKenna

Defendant

MGN Ltd

Claimant

Procedural Posture

Defamation / High Court Trial Judgment

Legal Issues

  1. 1 Whether the article published by MGN Ltd was defamatory of Paul McKenna
  2. 2 Whether the defamatory allegation was substantially true (justification)
  3. 3 Whether Paul McKenna fraudulently claimed a bogus PhD

Ratio Decidendi

The article published by MGN Ltd was defamatory of Paul McKenna in alleging that he fraudulently claimed a bogus PhD while knowing it was bogus. The defendant failed to prove to the civil standard that McKenna knew his degree was bogus or that he acted dishonestly. The evidence showed McKenna acted in good faith, submitted work, and was unaware of the university's lack of accreditation until after the fact. The defence of justification failed. Damages were awarded for injury to reputation and hurt feelings.

Court Disposition

Claimant succeeds. Judgment for Paul McKenna.

Orders

  • MGN Ltd to pay damages to Paul McKenna for libel.
  • MGN Ltd to pay costs.