Cases

McKenna v MGN Ltd

Facts

C, a well-known hypnotherapist, held a PhD from an institution in Louisiana, at one time known as La Salle University. In 1996, the President of this institution pleaded guilty to fraud on the basis that he had misled students into believing the institution was accredited for the granting of degrees, when in truth it was not. C’s doctorate was the subject of a number of articles written by journalists Victor Lewis-Smith and Paul Sparks between 1997 and 2003. C brought proceedings for libel in respect of an article appearing in The Mirror on 18 October 2003 published by D under the heading “It’s a Load of Doc and Bull.” He contended that words in the article meant that he had fraudulenty boasted in his publicity material that he had a PhD whilst knowing full well that it was bogus as he had obtained it merely in return for the payment of money. D pleaded justification, seeking to defend the meaning that C publicly claimed to possess a doctorate whilst knowing it was “bogus”.

Also