Sir James Dyson & Ors v Channel Four Television Corporation & Anor

Reference: [2022] EWHC 2718 (KB)

Court: High Court, King's Bench Division

Judge: Nicklin J

Date of judgment: 31 Oct 2022

Summary: Libel – reference – corporate claimants – defamatory meaning

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Appearances: Adam Wolanski KC - Leading Counsel (Defendant)  Gervase de Wilde (Defendant) 

Instructing Solicitors: SMB


The Claimants (Sir James Dyson, Dyson Technology Limited, and Dyson Limited) sued for libel over a broadcast on Channel 4 News concerning the treatment of workers at a factory in Malaysia operated by ATA,  a company that manufactured goods for Dyson. The Claimants alleged that the broadcast conveyed the meaning that they were all complicit in the abuse and torture of workers.

The questions of intrinsic reference and (in so far as the First Claimant was concerned) defamatory meaning were tried as preliminary issues. The Second and Third Claimants’ alternative case of extrinsic (innuendo) reference was not the subject of this trial.


(1) Did the broadcast refer way of intrinsic reference to the Second or Third Claimants?

(2) Did the broadcast bear any meaning defamatory of the First Claimant?


(finding for the Defendants on both issues)

(1) The broadcast did not refer by way of intrinsic reference to the Second or Third Claimants. Neither company was named in the broadcast. The words did not defame the entirety of the Dyson group, but instead only the Dyson company that has the agreement with, and therefore oversight of, ATA; and (potentially) the Dyson company that ran the Dyson PR operation. There was no pleaded basis for concluding that readers would (without extrinsic knowledge) understand the Second and Third Claimants to carry out these functions.

(2) The words did not defame the First Claimant. He only featured briefly in the programme and no reasonable reader would consider that he was being criticised in any way.


An important analysis of the principles of reference as applied to corporate claimants. The case underlines the need, where a specific corporate entity within a larger group structure is not named in a publication, to assess with care which specific corporate entity was being targeted by the words. This requires consideration of the nature of what is being alleged as well as the functions carried out by the corporate entity in question.

The judge explained that the issue of intrinsic reference may only rarely be suitable for trial as a preliminary issue. In this case, unusually, the matter could be tried without any evidence being heard. If evidence had been necessary the issue would have been less likely to be suitable for a preliminary trial.