Key Facts
- •Jeffrey John Hinds, a professional boxing referee licensed by the British Boxing Board of Control (BBBC), sued the BBBC for libel.
- •The libel stemmed from a statement on the BBBC's website: “The British Boxing Board of Control – Southern Area Council – June 2019 Notices – Regulation 25 – Jeff Hinds Given Words of Advice for the future.”
- •The case focused on preliminary issues: the meaning of the statement, whether it was defamatory, and whether it was fact or opinion.
- •The court determined the statement was one of fact, not opinion.
- •The claimant argued the statement implied wrongdoing, while the defendant argued it only meant Hinds received advice.
- •The court considered contextual evidence, including other notices on the BBBC website related to disciplinary actions.
Legal Principles
A statement is defamatory if its meaning tends to lower the claimant in the estimation of right-thinking people generally and would have a substantially adverse effect on how people treat the claimant.
Corbyn v. Millett, Monroe v. Hopkins
To ascertain the natural and ordinary meaning of a statement, the court applies principles from Koutsogiannis v. Random House Group Ltd, focusing on reasonableness and avoiding strained interpretations.
Koutsogiannis v. Random House Group Ltd, Corbyn v. Millett
Context in determining meaning is crucial but limited to material reasonably known to all recipients of the publication.
Brown v. Bower, Riley v. Murray
Outcomes
The court found the statement's meaning to be that Hinds was subject to disciplinary proceedings alleging misconduct, but was not found guilty or punished, only given advice.
The court considered the statement in the context of other similar notices on the BBBC website. The judge rejected the claimant's argument that the statement implied guilt, finding that a reasonable reader would understand the distinction between those punished and those merely advised.
The court held the statement was not defamatory.
The meaning of the statement did not lower Hinds' reputation among right-thinking people; therefore the behavior attributed to him was not contrary to shared societal values, and no adverse effect on how people would treat him was implied.