Reynolds v Times Newspapers Ltd [2001] 2 AC 127

Facts

• Albert Reynolds, former Irish Taoiseach, brought a defamation claim against The Sunday Times regarding allegations of misconduct published in an article about his political role.
• The case concerned the balance between protecting an individual's reputation and the freedom of the press to report on public interest matters.
• The House of Lords addressed whether journalists should be granted a defence when publishing defamatory material in the public interest, provided they acted responsibly.
• The published article was alleged to have damaged Reynolds’s reputation through accusations related to his conduct in office.

Issues

1. Whether the publication by The Sunday Times was defamatory of Albert Reynolds.
2. Whether journalists and publishers should have a qualified defence (later termed "Reynolds privilege") for defamatory statements made in the public interest.
3. What standards of responsible journalism are required to satisfy such a defence.
4. How courts should assess claims of public interest and responsible journalism using objective criteria.

Decision

• The House of Lords established the "Reynolds privilege," a qualified defence available to journalists and publishers reporting on matters of public interest, conditioned on responsible journalism.
• A ten-point test was introduced to assist courts in assessing whether the standards of responsible journalism were met for this defence.
• The defence is not absolute; the publisher must demonstrate the publication was both in the public interest and responsibly made.
• The case significantly influenced later defamation law and the balance between press freedom and protection of reputation.

Legal Principles

• Reynolds privilege provides a qualified defence to defamation for responsible journalism in matters of public interest.
• Courts should consider factors including the seriousness of the allegation, source credibility, verification steps, urgency, whether comment was sought from the claimant, article tone, and the broader public interest.
• The ten-point test guides courts in determining whether the standards of responsible journalism are satisfied.
• The defence seeks to support the democratic function of the press while retaining protection from irresponsible publication.

Conclusion

Reynolds v Times Newspapers Ltd [2001] 2 AC 127 marked a significant evolution in UK defamation law by recognising a qualified privilege for responsible journalism in the public interest, defined through an influential ten-point test and shaping the future interplay between media freedom and reputational protection.