Lewis v Daily Telegraph [1964] AC 234

Facts

  • Lewis, the plaintiff, was the subject of newspaper articles published by the Daily Telegraph which reported that he was under investigation by the Fraud Squad.
  • The articles stated that Lewis was being investigated but did not explicitly accuse him of fraud or misconduct.
  • Lewis alleged that the articles were defamatory because they implied his guilt, rather than merely reporting the existence of an investigation.
  • The case was heard by the House of Lords, focusing on the interpretation of the statements made in the publications.

Issues

  1. Whether the articles’ reference to a Fraud Squad investigation suggested to the ordinary, reasonable reader that Lewis was guilty of wrongdoing.
  2. How courts should determine the natural and ordinary meaning of words in alleged defamatory statements.
  3. Whether the context and presentation of the articles affected their potential defamatory meaning.

Decision

  • The House of Lords held that the statements did not impute guilt to Lewis but only conveyed that an investigation was underway.
  • The Court determined that the natural and ordinary meaning of the words must be assessed objectively, as understood by a reasonable reader.
  • The Court rejected the argument that mere reporting of an investigation implies guilt unless the language explicitly or implicitly supports that inference.
  • It was affirmed that liability for defamation requires more than unintended implications inferred by strained interpretation.

Legal Principles

  • The meaning of words in defamation must be judged by their natural and ordinary meaning to an ordinary, reasonable person.
  • Context, tone, style, and presentation of the publication are important in determining meaning.
  • Courts must avoid attributing innuendo or secondary meanings unless these are explicitly supported by the text.
  • Reporting factual information about investigations does not constitute defamation unless guilt or wrongdoing is expressly or impliedly imputed.
  • Defamation law must balance the protection of reputation with the right to freedom of expression.

Conclusion

Lewis v Daily Telegraph [1964] AC 234 established that in defamation law, courts must objectively assess whether statements are defamatory based on how a reasonable reader would interpret their natural and ordinary meaning in context, without inferring guilt where none is suggested, thereby providing critical protections for accurate reporting and fair public discourse.

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