Yeo v Times Newspapers Ltd [2015] EWHC 3375 (QB) (25 November 2015)

Yeo v Times Newspapers Ltd [2015] EWHC 3375 (QB) (25 November 2015)

The court found that Times Newspapers Limited failed to prove the substantial truth of the defamatory factual imputations that Mr Yeo was prepared to act, or had offered to act, in breach of the MPs' Code of Conduct as a paid Parliamentary advocate. The honest comment defence failed because the facts proved did not support the defamatory comment. The Reynolds privilege defence failed as the journalism was not responsible: the articles did not fairly and accurately reflect the totality of the evidence, and omitted or misrepresented material aspects of Mr Yeo's conduct and state of mind. The 23 June article was found to refer to Mr Yeo but was not justified or privileged.

Citation
[2015] EWHC 3375
Parties
Claimant: Tim Yeo; Defendant: Times Newspapers Limited
Jurisdiction
England and Wales
Judgment Date
25 November 2015
Procedural Posture
Defamation / High Court Trial, Judgment
Outcome
Claimant succeeds; defences of justification, honest comment, and Reynolds privilege all fail.
Legal Topics
Libel, Honest Comment, Reynolds Privilege, Paid Advocacy, Parliamentary Code of Conduct
Media Law Defamation Public Law Libel Honest Comment Reynolds Privilege Paid Advocacy Parliamentary Code of Conduct

Case Brief

Summary, issues, holding and outcome

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Parties

Tim Yeo

Claimant

Times Newspapers Limited

Defendant

Procedural Posture

Defamation / High Court Trial, Judgment

Legal Issues

  1. 1 Whether the articles published by Times Newspapers Limited were defamatory of Tim Yeo
  2. 2 Whether the defamatory factual imputations were substantially true (justification)
  3. 3 Whether the defamatory comments were honest comment

Ratio Decidendi

The court found that Times Newspapers Limited failed to prove the substantial truth of the defamatory factual imputations that Mr Yeo was prepared to act, or had offered to act, in breach of the MPs' Code of Conduct as a paid Parliamentary advocate. The honest comment defence failed because the facts proved did not support the defamatory comment. The Reynolds privilege defence failed as the journalism was not responsible: the articles did not fairly and accurately reflect the totality of the evidence, and omitted or misrepresented material aspects of Mr Yeo's conduct and state of mind. The 23 June article was found to refer to Mr Yeo but was not justified or privileged.

Court Disposition

Claimant succeeds; defences of justification, honest comment, and Reynolds privilege all fail.

Orders

  • Judgment for the claimant
  • Damages to be assessed