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Levi v Bates
Facts
C, a former director of Leeds United Football Club, sued D, the current Chairman of that club, for libel over comments published in progamme notes for the club's home games and a letter to club members. D defended the case on the interlocking bases of meaning, qualified privilege, justification and fair comment. There was no plea of malice. The case was tried by Sir Charles Gray, sitting, without a jury, as a Judge of the High Court.