Cases

Wood v Chief Constable of West Midlands Police (CA)

Held

(1) The publications were not made on occasions of qualified privilege. The police have a public duty to detect and prevent crime and protect potential victims, but disclosure of damaging information about individuals requires specific public interest justification and should therefore be for the purpose and to the extent necessary for the performance of their public duties: see R v Chief Constable of North Wales ex p Thorpe [1999] QB 396 (which "illuminated, without necessarily defining" the duty contended for). The publications did not sufficiently contribute to the prevention of crime or the protection of victims to sustain a duty of disclosure. The fact that H had been arrested but not convicted required "particular care". "The police had no business, let alone duty, to make statements anticipating that he would be convicted." (2) The Judge had acted properly within his discretion in permitting the slander amendment.

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