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Angel v Stainton & Another
Comment
This is another example (like Campbell-James v Guardian Media Group plc) where a defendant has lost the full benefit of the deflationary effect of an offer of amends by a grave error of judgment in persisting in correspondence in an unsustainable defence of 'fair comment', as opposed to making a full acceptance that the allegation is false and defamatory. A defendant must be careful properly to assess if there is truly any legitimate background material which might mitigate the award under Burstein principles, lest the effort to mitigate just makes matters worse.