Injunctions 101 – hyper, super or anonymised?
Hardly a day has gone by without coverage in the media of privacy injunctions. It is a subject that has excited the media, from The Star to The Times. But what is the difference between 'super', 'hyper' and 'anonymised' injunctions, and is all the media fuss really justified?
May 11, 2011 at 07:03 PM
4 minute read
Hardly a day has gone by without coverage in the media of privacy injunctions. It is a subject that has excited the media, from The Star to The Times. But what is the difference between 'super', 'hyper' and 'anonymised' injunctions, and is all the media fuss really justified?
The term 'superinjunction' was first used by The Guardian in the Trafigura case against them in 2009. It not only anonymised the details of the claimant, but the 'super' part prohibited publication of all information relating to the proceedings or the intended claim. Prior to the Human Rights Act (HRA) of 1998, there was no protection of privacy, with individuals relying on the law of confidence. But as a number of the early kiss-and-tell cases showed, that law did not protect more general areas of people's private lives.
Lord Phillips was the first to use the phrase "misuse of private information" in Campbell v MGN. A number of other cases confirmed the development of the area of law, in particular Douglas and Hello and McKennitt v Ash. In McKennitt, Mr Justice Eady posed questions for the court to consider and which the Court of Appeal has followed on numerous occasions.
First, is the information private in the sense that it is in principle protected by article 8? If no, that is the end of the case. If yes, the second question arises: in all the circumstances, must the interest of the owner of private information yield to the right of freedom of expression confirmed on the publisher by article 10? However uneasy David Cameron may feel about what he considers to be "a judge-made law of privacy", these are the questions that Parliament would have to wrestle with, and which it acknowledged was the position before the HRA.
If information is so private that it is to be protected by an injunction, then to have real force the names of the parties must be anonymised and, in certain circumstances, reporting of the injunction prohibited. The court has made clear, following the Trafigura case, that these should now only be made in very limited circumstances.
In DFT v TFD, Mrs Justice Sharp refused to continue a superinjunction that had been granted to prevent the notification of a blackmailer, making instead what has now become known as a DFT order limiting publication to what is contained in the order and public judgment. The Court of Appeal's discharge of the superinjunction in Ntuly v Donald, and the guidance given in the case of JIH v News Group Newspapers Ltd, indicate that a superinjunction at first instance seems very unlikely.
But the recent cases of ETK v News Group Newspapers and the recent contra mundum order of Mr Justice Eady in OPQ v BJM led to so much speculation on the internet that David Aaronovitch of The Times said "it took me 15 minutes of Googling to see who the injunctors were". He accepted that "if people who sleep with other people are to have their stories printed and discussed in the media, then there really is no privacy for the complainant. More, it seems to me that the public interest argument in these cases now amounts to little more than 'he's rich and famous, so he deserves it'."
This really is at the heart of the issue. Kiss-and-tell is not of public interest, but of interest to the public. The media should not be able to use article 10 rights as a trump card to defeat the individual's article 8 rights against the misuse of private information by turning such anonymised privacy injunctions into celebrity scrabble.
And what of hyperinjunctions? This appears to be a term introduced by John Hemming MP in a debate in March 2011 describing an injunction prohibiting a person from contacting his MP. The only example of its use was in a commercial case from 2006, and appears to be unconnected with privacy law. We await the Master of the Rolls' report, but I anticipate that this is not an issue that Parliament will be any more willing to tackle now than it was when the HRA was introduced.
Sarah Webb is a partner at Payne Hicks Beach.
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