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Armstrong v Times Newspapers Ltd & Others (QB)
Comment
The ruling on meaning shows that Chase Level 3 meanings are difficult to establish, particularly if there is no ongoing investigation. An article which attempts to set out the facts into which it is said there should be an investigation can well end up suggesting grounds to suspect or worse guilt. Eady J's comments on the limits of admissible evidence under a Level 3 meaning - citing Sedley LJ in Jameel - are worthy of note. The application for a costs-capping order - the first since Musa King - was unsuccessful because, absent a CFA and facing a wealthy Claimant, the Defendants were adequately protected against any alleged extravagance by the Claimant by the usual retrospective assessment of costs.