Key Facts
- •Muhammad Zia Ullah Khan Chishti (Claimant) sued Tatiana Spottiswoode, Nancy Smith, and Telegraph Media Group Limited (Third Defendant) for libel.
- •The claim against the First and Second Defendants was withdrawn.
- •The libel claim concerns two articles published by the Third Defendant on November 27th and 28th, 2021.
- •The articles allege sexual misconduct by the Claimant towards Tatiana Spottiswoode.
- •The court considered preliminary issues of the articles' meaning and whether they were defamatory.
- •The Claimant's pleaded meaning was that he groomed Spottiswoode for sex since she was 13.
- •The Defendant's contended meaning was that there were grounds to suspect grooming from age 21.
Legal Principles
Determination of the single natural and ordinary meaning of words in libel proceedings.
Koutsogiannis v Random House Group [2020] 4 WLR 25
The hypothetical reasonable reader's perspective, considering context but avoiding over-elaborate analysis or strained interpretations.
Koutsogiannis v Random House Group [2020] 4 WLR 25; Riley v Murray [2020] EWHC 977 (QB)
Categorization of allegations of wrongdoing (guilty, reasonable suspicion, grounds to investigate).
Chase v News Group Newspapers [2003] EMLR 11 [45]
The repetition rule: repeating another's allegation amounts to republication, even with attribution.
Brown v Bower [2017] EWHC 2637 (QB); Hewson v Times Newspapers Ltd [2019] EWHC 650 (QB)
Test for defamatory meaning: whether it substantially affects the attitude of others towards the claimant.
Outcomes
The single natural and ordinary meaning of both articles is that the Claimant groomed Tatiana Spottiswoode with sexual intent since she was 13, and engaged in an abusive relationship with her after she became an adult.
The court considered the articles' text, headlines, subheadings, and context. While acknowledging the Defendant's arguments, the judge found their interpretation to be strained and that the ordinary reader would understand the articles to impute grooming from age 13.
The meaning is a Chase level 1 factual imputation and is defamatory.
The allegations are factual, not opinion, and at the highest level of seriousness in the Chase categorisation.