Key Facts
- •Richard D Hall (Appellant) denied the Manchester Arena bombing, claiming it was a staged event by the UK government.
- •Martin and Eve Hibbert (Respondents), victims of the bombing, sued Hall for harassment, misuse of private information, and data protection violations.
- •Hall's publications and actions, including secretly filming Eve Hibbert, formed the basis of the Respondents' claim.
- •Master Davison granted summary judgment to the Respondents on four key issues: the occurrence of the bombing, the Respondents' presence at the Arena, their injuries, and the cause of their injuries.
- •Hall's renewed application for permission to appeal was dismissed by Mr Justice Julian Knowles.
Legal Principles
Summary judgment test under CPR Part 24.
CPR Part 24, Easyair Ltd v Opal Telecom Ltd [2009] EWHC 339 (Ch), AC Ward & Sons Ltd v Catlin (Five) Ltd [2009] EWCA Civ 1098
Evidential burden of proof in summary judgment applications.
Korea National Insurance Corp v Allianz Global Corporate & Speciality AG [2007] EWCA Civ 1066
Admissibility of criminal convictions in civil proceedings (Section 11, Civil Evidence Act 1968).
Section 11, Civil Evidence Act 1968; CXX v DXX [2012] EWHC 1535 (QB)
Outcomes
Master Davison granted summary judgment to the Respondents on all four issues.
The Master found Hall's claims to be 'absurd and fantastical,' and insufficient to rebut the evidence of Hashem Abedi's conviction and the Respondents' evidence.
Steyn J refused permission to appeal.
Steyn J found no real prospect of success on appeal, noting the weight of evidence supporting the Respondents' case, including Hashem Abedi's conviction and the Respondents' evidence.
Mr Justice Knowles dismissed the renewed application for permission to appeal.
Knowles J agreed with the Master's and Steyn J's analyses, finding the application without merit and the appeal without prospects of success. He highlighted the proper application of Section 11 of the Civil Evidence Act 1968 and the inadequacy of Hall's evidence.