Yeo v Times Newspapers Ltd [2015] EWHC 2132 (QB) (22 July 2015)

Yeo v Times Newspapers Ltd [2015] EWHC 2132 (QB) (22 July 2015)

The court declined to set ground rules on Parliamentary Privilege in the abstract, held that references to Parliamentary proceedings and findings must be removed from the claimant's evidence and pleadings, refused to strike out the claim regarding the 23 June article as it was not plain and obvious it could not succeed, and refused to approve the claimant's revised costs budget as there was no significant development in the litigation justifying it.

Citation
[2015] EWHC 2132 (QB)
Parties
Claimant: Tim Yeo; Defendant: Times Newspapers Limited
Jurisdiction
England and Wales
Judgment Date
22 July 2015
Procedural Posture
Libel Action / Pre Trial Review
Outcome
Applications to strike out or summarily dismiss the 23 June article claim refused; references to Parliamentary proceedings and findings to be removed from claimant's evidence and pleadings; application to approve revised costs budget refused except for agreed item.
Legal Topics
Libel, Parliamentary Privilege, Costs Budgeting, Aggravated Damages, Responsible Journalism, Fair Comment, Public Interest Defence

Case Brief

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Parties

Tim Yeo

Claimant

Times Newspapers Limited

Defendant

Procedural Posture

Libel Action / Pre Trial Review

  1. 1 Application of Article 9 of the Bill of Rights 1689 (Parliamentary Privilege) to libel proceedings
  2. 2 Admissibility of evidence relating to Parliamentary proceedings
  3. 3 Whether the claim regarding the 23 June 2013 article should be struck out or summarily dismissed

Ratio Decidendi

The court declined to set ground rules on Parliamentary Privilege in the abstract, held that references to Parliamentary proceedings and findings must be removed from the claimant's evidence and pleadings, refused to strike out the claim regarding the 23 June article as it was not plain and obvious it could not succeed, and refused to approve the claimant's revised costs budget as there was no significant development in the litigation justifying it.

Court Disposition

Applications to strike out or summarily dismiss the 23 June article claim refused; references to Parliamentary proceedings and findings to be removed from claimant's evidence and pleadings; application to approve revised costs budget refused except for agreed item.

Orders

  • Claimant to remove references to Parliamentary proceedings and findings from evidence and pleadings.
  • Claimant's application for approval of revised costs budget refused except for agreed additional £450 for trial.