Smart Shirts Ltd v Sheffield Hallam University [2025] EWHC 1353 (KB) (22 May 2025)

Smart Shirts Ltd v Sheffield Hallam University [2025] EWHC 1353 (KB) (22 May 2025)

The natural and ordinary meaning of both the E-Mail and the Report is that there are grounds to investigate whether the Claimant knew or should have known it was sourcing raw materials or supplies that were the product of forced labour from the Xinjiang Uyghur Autonomous Region; these meanings are defamatory of the Claimant at common law. Annex A is not to be treated as part of the publication for the purposes of meaning due to the convoluted access process and lack of sufficient connection.

Citation
[2025] EWHC 1353 (KB)
Parties
Claimant: Smart Shirts Limited; Defendant: Sheffield Hallam University
Jurisdiction
England and Wales
Judgment Date
22 May 2025
Procedural Posture
Libel Claim (defamation) / Retrial of Preliminary Issues as to Meaning
Outcome
Preliminary issues determined: the natural and ordinary meanings found as set out in the judgment; both publications are defamatory of the Claimant at common law.
Legal Topics
Libel, Natural and Ordinary Meaning, Defamatory Meaning, Supply Chain Due Diligence, Forced Labour Allegations, Chase Level Meanings, Online Publication Context
Defamation Media Law Libel Natural and Ordinary Meaning Defamatory Meaning Supply Chain Due Diligence Forced Labour Allegations Chase Level Meanings +1 more

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 14 Party arguments 2
Sign in to unlock

Parties

Smart Shirts Limited

Claimant

Sheffield Hallam University

Defendant

Procedural Posture

Libel Claim (defamation) / Retrial of Preliminary Issues as to Meaning

Legal Issues

  1. 1 What is the natural and ordinary meaning of the E-Mail and the Report as complained of?
  2. 2 Are the words complained of defamatory of the Claimant at common law?
  3. 3 Should Annex A be treated as part of the publication for the purposes of meaning?

Ratio Decidendi

The natural and ordinary meaning of both the E-Mail and the Report is that there are grounds to investigate whether the Claimant knew or should have known it was sourcing raw materials or supplies that were the product of forced labour from the Xinjiang Uyghur Autonomous Region; these meanings are defamatory of the Claimant at common law. Annex A is not to be treated as part of the publication for the purposes of meaning due to the convoluted access process and lack of sufficient connection.

Court Disposition

Preliminary issues determined: the natural and ordinary meanings found as set out in the judgment; both publications are defamatory of the Claimant at common law.

Orders

  • Annex A excluded from consideration for meaning.
  • Parties to amend statements of case as required to reflect the Court's findings on meaning.