Coulter v Sunday Newspapers Ltd [2017] NICA 10 (20 February 2017)

Coulter v Sunday Newspapers Ltd [2017] NICA 10 (20 February 2017)

The trial judge erred in treating the impugned statements as assertions of fact rather than comment, thereby failing to consider the honest comment defence. This misdirection requires the judgment to be set aside and a retrial ordered.

Citation
[2017] NICA 10
Parties
Plaintiff/respondent: Robert James Gordon Coulter; Defendant/appellant: Sunday Newspapers Ltd
Jurisdiction
Northern Ireland
Judgment Date
20 February 2017
Procedural Posture
Civil Appeal Defamation / Appeal From High Court Judgment and Order
Outcome
Appeal allowed; order set aside; retrial ordered.
Legal Topics
Single Meaning Rule, Fact Vs Comment, Honest Comment Defence, Reynolds Privilege, Public Interest, Responsible Journalism, Quantum of Damages

Case Brief

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Parties

Robert James Gordon Coulter

Plaintiff/respondent

Sunday Newspapers Ltd

Defendant/appellant

Procedural Posture

Civil Appeal Defamation / Appeal From High Court Judgment and Order

  1. 1 Whether the trial judge erred in treating statements as fact rather than comment
  2. 2 Whether the single meaning rule was properly applied
  3. 3 Whether the honest comment defence should have been considered

Ratio Decidendi

The trial judge erred in treating the impugned statements as assertions of fact rather than comment, thereby failing to consider the honest comment defence. This misdirection requires the judgment to be set aside and a retrial ordered.

Court Disposition

Appeal allowed; order set aside; retrial ordered.

Orders

  • Order in favour of respondent quashed
  • Retrial before a different judge directed