Budu v The British Broadcasting Corporation [2010] EWHC 616 (QB) (23 March 2010)

Budu v The British Broadcasting Corporation [2010] EWHC 616 (QB) (23 March 2010)

The articles and Google snippet are incapable of bearing the pleaded defamatory meanings, particularly the 'security risk' meaning. The BBC cannot be liable for the Google snippet as it does not repeat any actionable defamatory sting from the original articles. The action is an abuse of process as there is no real...

Source-derived case information.

Citation
[2010] EWHC 616
Parties
Claimant: Samuel Kingsford Budu; Defendant: The British Broadcasting Corporation
Jurisdiction
England and Wales
Judgment Date
23 March 2010
Procedural Posture
Libel Action / Application to Strike Out And/or Summary Judgment Prior to Defence
Outcome
Action struck out as abuse of process; summary judgment granted for BBC
Legal Topics
Libel, Online Publication, Republication Liability, Limitation Period, Meaning of Defamatory Statements, Abuse of Process
Defamation Media Law Civil Procedure Libel Online Publication Republication Liability Limitation Period Meaning of Defamatory Statements +1 more

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Parties

Samuel Kingsford Budu

Claimant

The British Broadcasting Corporation

Defendant

Procedural Posture

Libel Action / Application to Strike Out And/or Summary Judgment Prior to Defence

Legal Issues

  1. 1 Whether the articles and Google snippet are capable of bearing the defamatory meanings pleaded
  2. 2 Whether the BBC is liable for republication via Google snippet
  3. 3 Whether the action should be struck out as abuse of process

Ratio Decidendi

The articles and Google snippet are incapable of bearing the pleaded defamatory meanings, particularly the 'security risk' meaning. The BBC cannot be liable for the Google snippet as it does not repeat any actionable defamatory sting from the original articles. The action is an abuse of process as there is no real and substantial tort to be tried.

Court Disposition

Action struck out as abuse of process; summary judgment granted for BBC

Orders

  • Claim dismissed
  • BBC not liable for Google snippet