Cases

Warren v The Random House Group Ltd

Facts

C brought a libel claim in respect of three allegations in the book “Ricky Hatton: The Hitman, My Story” published by D.

D sought to justify two of the allegations, but made an offer of amends in relation to the third allegation, that C had conned a boxer into accepting an unfairly low fee for a fight. D relied on and pleaded Burstein particulars in relation to this allegation. The offer of amends was accepted and an agreed statement in open court was made.

D subsequently obtained additional evidence and sought to substitute the offer of amends with a plea of justification. D contended that:

(1) s.2(2) Defamation Act 1996 did not entitle a defendant to make an offer of amends in respect of a selected passage of a book where the book contained several separate defamatory imputations; and

(2) disabling a defendant from defending itself in relation to a claim in which an offer of amends had been accepted was an interference with the D’s Arts 10 and 6 ECHR rights.

Also