Waterson v Lloyd & Anor [2011] EWHC 3197 (QB) (08 December 2011)

The publications complained of bear the meaning that the claimant was guilty of abuse of Parliamentary rules for his own financial advantage, which is defamatory and constitutes a statement of fact, not comment or opinion; therefore, summary judgment must be entered for the claimant as the defence of honest comment is not available.

Citation: [2011] EWHC 3197
Parties: Claimant: Nigel Waterson; Defendant: Stephen Lloyd MP; Defendant: Rebecca Carr
Jurisdiction: England and Wales
Judgment Date: 08 December 2011
Procedural Posture: Libel Action / Summary Judgment on Liability
Outcome: Judgment for claimant on liability; relief to be determined separately
Legal Topics: Libel, Distinction Between Fact and Comment, Mps' Expenses Scandal, Fair Comment Defence, Election Publications

Defamation Media Law Election Law Libel Distinction Between Fact and Comment Mps' Expenses Scandal Fair Comment Defence Election Publications

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Full judgment text Downloadable case file Legal principles 3 Authorities cited 9 Party arguments 2 Amounts and remedies 11

Parties

Nigel Waterson

Claimant

Stephen Lloyd MP

Defendant

Rebecca Carr

Defendant

Procedural Posture

Libel Action / Summary Judgment on Liability

Legal Issues

1 What is the meaning of the publications complained of?
2 Are the statements fact or comment/opinion?
3 Are the statements defamatory?

Ratio Decidendi

Court Disposition

Judgment for claimant on liability; relief to be determined separately

Orders

Summary judgment entered for claimant on liability
Issues as to relief (damages or other) to be determined later if not agreed