M'Lean v. Hart [1908] ScotLR 874 (11 July 1908)

M'Lean v. Hart [1908] ScotLR 874 (11 July 1908)

The pursuer failed to aver facts and circumstances from which malice could be inferred; the defender's statements were relevant and privileged, made in support of his case, with no evidence of indirect malicious motive. The action was therefore irrelevant and must be dismissed.

Citation
[1908] ScotLR 874
Parties
Pursuer/respondent: William C. M'Lean; Defender/reclaimer: Patrick Campbell Hart
Jurisdiction
Scotland
Judgment Date
11 July 1908
Procedural Posture
Action for Damages for Judicial Slander / Inner House Appeal; Interlocutor of Lord Ordinary Recalled
Outcome
Defender assoilzied; action dismissed
Legal Topics
Judicial Slander, Privilege, Malice, Averment of Facts and Circumstances

Case Brief

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Parties

William C. M'Lean

Pursuer/respondent

Patrick Campbell Hart

Defender/reclaimer

Procedural Posture

Action for Damages for Judicial Slander / Inner House Appeal; Interlocutor of Lord Ordinary Recalled

  1. 1 Whether facts and circumstances sufficient to infer malice were averred in an action for judicial slander
  2. 2 Whether statements made in pleadings are privileged when pertinent to the action

Ratio Decidendi

The pursuer failed to aver facts and circumstances from which malice could be inferred; the defender's statements were relevant and privileged, made in support of his case, with no evidence of indirect malicious motive. The action was therefore irrelevant and must be dismissed.

Court Disposition

Defender assoilzied; action dismissed

Orders

  • Lord Ordinary's interlocutor recalled
  • Defender assoilzied from conclusions of the action