Speedie -v- Sunday Newspapers Ltd & Ors [2017] IECA 15 (02 February 2017)

Speedie -v- Sunday Newspapers Ltd & Ors [2017] IECA 15 (02 February 2017)

The single meaning rule was not breached as the publication contained two distinct allegations conveyed by different words; the newspaper was estopped from raising the s. 16(2) defence due to its failure to do so in a timely manner; the quantum of damages awarded was appropriate and not disproportionate.

Citation
[2017] IECA 15
Parties
Respondent/plaintiff: David Speedie; Appellant/defendant: Sunday Newspapers Ltd.; Appellant/defendant: Colm McGinty; Appellant/defendant: Mick McCaffrey
Jurisdiction
Ireland
Judgment Date
02 February 2017
Procedural Posture
Civil Appeal / Appeal From Jury Verdict in Defamation Action
Outcome
Appeal dismissed
Legal Topics
Single Meaning Rule, Defence of Truth, Section 16(2) Defamation Act 2009, Jury Directions, Quantum of Damages
Defamation Media Law Tort Single Meaning Rule Defence of Truth Section 16(2) Defamation Act 2009 Jury Directions Quantum of Damages

Case Brief

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Parties

David Speedie

Respondent/plaintiff

Sunday Newspapers Ltd.

Appellant/defendant

Colm McGinty

Appellant/defendant

Mick McCaffrey

Appellant/defendant

Procedural Posture

Civil Appeal / Appeal From Jury Verdict in Defamation Action

Legal Issues

  1. 1 Whether the single meaning rule was breached by allowing multiple meanings to go to the jury
  2. 2 Whether the sequence of jury questions deprived the defendants of a s. 16(2) defence under the Defamation Act 2009
  3. 3 Whether the quantum of damages awarded was appropriate

Ratio Decidendi

The single meaning rule was not breached as the publication contained two distinct allegations conveyed by different words; the newspaper was estopped from raising the s. 16(2) defence due to its failure to do so in a timely manner; the quantum of damages awarded was appropriate and not disproportionate.

Court Disposition

Appeal dismissed

Orders

  • Jury award of €85,000 to plaintiff affirmed
  • No alteration to quantum of damages