Key Facts
- •Sean Price, a former Chief Constable of Cleveland Police, sued Newsquest Media Group Limited for libel.
- •The libel concerned two articles published in April 2022, alleging Price's implication in scandals during his tenure.
- •The articles mentioned Price's dismissal for gross misconduct, unlawful phone monitoring of journalists, and racism within the force.
- •A preliminary issues trial was held to determine the meaning of the publications and whether they were defamatory.
Legal Principles
Determining the natural and ordinary meaning of words in a libel case.
Millett v Corbyn [2021] E.M.L.R. 19 at [8]; Koutsogiannis v Random House Group Limited [2020] 4 W.L.R. 25 at [11]–[12]
A meaning is defamatory if it substantially affects the attitude of others towards the claimant.
Triplark v Northwood Hall [2019] EWHC 3494 (QB) at [11]
The court considers the hypothetical reasonable reader, who is not naïve but not unduly suspicious.
Koutsogiannis v Random House Group Limited [2020] 4 W.L.R. 25 at [11]–[12]
The publication must be read as a whole, considering 'bane and antidote'.
Koutsogiannis v Random House Group Limited [2020] 4 W.L.R. 25 at [11]–[12]
Outcomes
The court determined the natural and ordinary meaning of the publications.
The court found that the articles implied Sean Price was implicated in the unlawful phone monitoring and racism issues, in addition to his dismissal for gross misconduct. The lack of clear separation between these points in the articles created this connection in the mind of the reasonable reader.
The court found the meaning to be defamatory.
The court determined the meaning would negatively affect others' attitudes towards Mr. Price.
The claimant was ordered to pay costs related to amending the Particulars of Claim.
The amendments were deemed necessary due to flaws in the original pleadings.