Cases

Wakefield v Channel Four Television & Others

Held

(1) the Channel 4 proceedings should not be stayed. Whilst there might be an overlap of issues between the libel and GMC proceedings, findings in the latter would not be determinative of (or even admissible in) the former. In addition the Defendants' Article 6 rights entitled them to have the claim tried within a reasonable period (Johnson v Gore Wood & Co [2002] 2 AC 1 considered): particularly when the Claimant had been using the stayed proceedings to his advantage while not wishing to progress them or to give the Defendants an opportunity of meeting the claims; (2) the website proceedings would be stayed pending the determination of the Channel 4 proceedings. The outcome of those proceedings was likely to be determinative of the others. It was inconsistent with the principle of equality of arms to make Mr Deer, a litigant in person in the website proceedings, to have to progress a case when he had the benefit of legal representation in the Channel 4 proceedings.

Also