Smart Shirts Ltd v Sheffield Hallam University (Rev1) [2024] EWHC 3276 (KB) (17 December 2024)

Smart Shirts Ltd v Sheffield Hallam University (Rev1) [2024] EWHC 3276 (KB) (17 December 2024)

Both the email and the report bear a Chase level 2 meaning: there are reasonable grounds to suspect Smart Shirts is, by association with Zhejiang Sunrise, involved directly or indirectly in sourcing materials tainted by forced labour from XUAR. Both meanings are of fact, ongoing in nature, and defamatory at common law. Annex A is part of the report but would not materially affect the ordinary reasonable reader's understanding of the sting of the report.

Citation
[2024] EWHC 3276 (KB)
Parties
Claimant: Smart Shirts Limited; Defendant: Sheffield Hallam University
Jurisdiction
England and Wales
Judgment Date
17 December 2024
Procedural Posture
Libel Claim (defamation) / Preliminary Issues Trial on Meaning
Outcome
Determination of meaning only; both publications found to bear a Chase level 2 defamatory meaning at common law.
Legal Topics
Libel, Meaning of Publication, Chase Levels, Defamatory Meaning, Supply Chain Human Rights Abuses

Case Brief

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Parties

Smart Shirts Limited

Claimant

Sheffield Hallam University

Defendant

Procedural Posture

Libel Claim (defamation) / Preliminary Issues Trial on Meaning

  1. 1 What is the single natural and ordinary meaning of the email and report complained of?
  2. 2 Are the meanings defamatory at common law?
  3. 3 What is the Chase level of meaning for each publication?

Ratio Decidendi

Both the email and the report bear a Chase level 2 meaning: there are reasonable grounds to suspect Smart Shirts is, by association with Zhejiang Sunrise, involved directly or indirectly in sourcing materials tainted by forced labour from XUAR. Both meanings are of fact, ongoing in nature, and defamatory at common law. Annex A is part of the report but would not materially affect the ordinary reasonable reader's understanding of the sting of the report.

Court Disposition

Determination of meaning only; both publications found to bear a Chase level 2 defamatory meaning at common law.

Orders

  • Costs in the case.