Langlands v. John Leng & Co., Ltd [1916] UKHL 212 (21 January 1916)

Langlands v. John Leng & Co., Ltd [1916] UKHL 212 (21 January 1916)

The words used in the article and report were not reasonably capable of bearing the innuendo that the pursuer acted corruptly for his personal benefit; the criticism was directed at the system and not at the pursuer's personal integrity. Therefore, the issue should not be submitted to a jury and the action must be dismissed.

Citation
[1916] UKHL 212
Parties
Pursuer: James Hendry Langlands; Defenders: John Leng & Company, Limited
Jurisdiction
United Kingdom
Judgment Date
21 January 1916
Procedural Posture
Civil Appeal / Appeal to House of Lords From Second Division, Court of Session
Outcome
appeal allowed; action dismissed
Legal Topics
Slander, Libel, Innuendo, Fair Comment, Public Official Criticism
Defamation Media Law Tort Slander Libel Innuendo Fair Comment Public Official Criticism

Case Brief

Summary, issues, holding and outcome

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Parties

James Hendry Langlands

Pursuer

John Leng & Company, Limited

Defenders

Procedural Posture

Civil Appeal / Appeal to House of Lords From Second Division, Court of Session

Legal Issues

  1. 1 Whether the newspaper article and report published by the defenders were capable of bearing the innuendo that the pursuer, as architect to the School Board, acted corruptly for his personal benefit or made similar false and calumnious representations.
  2. 2 Whether the issue should be submitted to a jury or dismissed as not reasonably capable of supporting the defamatory innuendo.

Ratio Decidendi

The words used in the article and report were not reasonably capable of bearing the innuendo that the pursuer acted corruptly for his personal benefit; the criticism was directed at the system and not at the pursuer's personal integrity. Therefore, the issue should not be submitted to a jury and the action must be dismissed.

Court Disposition

appeal allowed; action dismissed

Orders

  • Interlocutor of the Second Division reversed.
  • Action dismissed with expenses in the House of Lords and the Courts below.