Full case report

Purnell v Business F1 Magazine Ltd & Another

Reference 14/03/2006
Court Queen's Bench Division

Judge Eady J

Date of Judgment 14 Mar 2006


Summary

Libel – Allegation of bribery – Justification – Summary judgment – CPR Part 24


Facts

The Claimant was head of the Formula 1 team Jaguar Racing until January 2005. The First Defendant owns Business F1 magazine and the Second Defendant is its editor. In April 2005 the magazine published an article which alleged that the Claimant had bribed a Formula 1 journalist in order to get positive press coverage to which he was not properly entitled.


Issue

Whether the Defendants’ evidence of justification had a reasonable prospect of success.


Held

Even if one assumed that all of the factual assertions made in the Defendants’ witness statements were true, a jury would be perverse to conclude that a bribe had in fact been paid.


Comment

This is a rare example of a case where the evidence put forward by a defendants on justification is so weak that summary judgment is granted. The Claimant went on to be awarded £75,000 by a jury at the quantum trial.


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Instructing Solicitors

Steeles for the Claimant; the Second Defendant in person for the Defendants