Waterson v Lloyd MP & Anor
The majority held that the publications constituted comment based on identified facts, not defamatory statements of fact; the meaning was that Mr Waterson claimed substantial sums for a home distant from his constituency, which the writers considered a scandal. There was no imputation of unlawful conduct or breach of rules. The appeal was allowed.
- Parties
- Respondent: Nigel Waterson; Appellant: Stephen Lloyd MP; Appellant: Rebecca Carr
- Jurisdiction
- England and Wales
- Judgment Date
- 28 February 2013
- Procedural Posture
- Civil Appeal / Court of Appeal Judgment
- Outcome
- Appeal allowed
- Legal Topics
- Libel, Honest Comment, Fair Comment, Political Speech, Meaning of Publication
Case Brief
Summary, issues, holding and outcome
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Parties
Nigel Waterson
Respondent
Stephen Lloyd MP
Appellant
Rebecca Carr
Appellant
Procedural Posture
Civil Appeal / Court of Appeal Judgment
Legal Issues
- 1 Whether campaign publications about Nigel Waterson constituted defamatory statements of fact or comment
- 2 Whether the defence of honest comment applies to the publications
- 3 Determination of the natural and ordinary meaning and innuendo meaning of the words complained of
Ratio Decidendi
The majority held that the publications constituted comment based on identified facts, not defamatory statements of fact; the meaning was that Mr Waterson claimed substantial sums for a home distant from his constituency, which the writers considered a scandal. There was no imputation of unlawful conduct or breach of rules. The appeal was allowed.
Court Disposition
Appeal allowed
Orders
- First appeal allowed; summary judgment for Mr Waterson set aside
Full Case Text
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