Supreme Court upholds right to comment defence in key libel case
The Supreme Court has overruled a lower court judgment that could have limited the use of right to comment defences, in the first major defamation case to be heard by the body. The Supreme Court unanimously overturned an earlier ruling from the Court of Appeal that blocked a booking agent that criticised a former client for "unprofessional" behaviour on its website from using a fair comment defence in libel proceedings.
December 01, 2010 at 09:19 AM
3 minute read
The Supreme Court has overruled a lower court judgment that could have limited the use of right to comment defences, in the first major defamation case to be heard by the body.
The Supreme Court unanimously overturned an earlier ruling from the Court of Appeal that blocked a booking agent that criticised a former client for "unprofessional" behaviour on its website from using a fair comment defence in libel proceedings.
The closely-watched ruling, which was handed down by Lord Phillips, also called for the fair comment defence to be renamed "honest comment" and recommended that the area be reviewed by an "expert committee" or the Law Commission.
The case, Spiller and another (Appellants) v Joseph and others (Respondents), involved a defamation claim pursued against the agent 1311 Events by a Motown tribute band known as The Gillettes or Saturday Night at the Movies. Members of The Gillettes launched the claim after 1311 Events on its website criticised the band's behaviour in a dispute regarding a booking.
The High Court initially struck out the agent's defence of fair comment and justification, while the Court of Appeal reinstated the justification defence but upheld the striking out of a fair comment defence.
The court also rejected part of a controversial 2001 ruling, Tse Wai Chun v Albert Cheung, which found that a fair comment defence should only be available where the commentator had made enough factual information available to allow readers to independently judge the nature of the remark.
In its place the court recommended that the "fourth proposition" in the Tse Wai case put forward by Lord Nicholls be rewritten as: "The comment must explicitly or implicitly indicate, at least in general terms, the facts on which it is based."
The ruling will be welcomed by campaigners for free speech and libel reform with critics of Nicholls' earlier ruling arguing that his test would fail to protect much of the debate on the internet.
Commenting on the ruling, 1 Crown Office Row barrister Adam Wagner said on the UK Human Rights Blog: "The decision will be a relief to those who think that Britain's libel laws are too tough and that the fair comment defence – an important element of free speech rights – has become too difficult to deploy. Presumably, [the recommendation for a review of fair comment] will be on the agenda for Lord Neuberger's upcoming review of libel law."
1131 Events was represented by David Price of David Price solicitors, while the respondents were advised by Pattinson & Brewer with 5RB's William Bennett instructed as counsel.
Reynolds Porter Chamberlain advised the interveners Daily Mail, Times Newspapers and Guardian Media Group in support of the appellant. One Brick Court's Andrew Caldecott QC was instructed as counsel.
For more, see 1 Crown Office Row barrister Adam Wagner's analysis from the UK Human Rights Blog.
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