Qualified Privilege
QUALIFIED PRIVILEGE (QP) - AN IMPORTANT DEFENCE AGAINST LIBEL ACTIONS

libel and qualified provilege, media law

These are rough lecture notes and do not constitute legal advice. The lecture must be taken in conjunction with the directed reading and your own research and verification. Last updated in October 2009.

(1) In reporting court, parliament you have a QP defence automatically when repeat/publish/broadcast defamatory remarks

(2) QP requires immediate publication, no errors, no malice ('fast, accurate, fair') Malice can be lack of balance, so add "he denies the charges" and "the case continues".

(3) You never have AP as a journalist, though in practice if your report is free from error, and if it published immediately then the QP confers a similar degree of protection.

(4) You have QP at a range of other public events (eg local government meetings, pressure group meetings, AGMs of companies - section 12 of the 1996 act + Clegg + Human Rights Act, section 10) so long as you allow the defamed person to deny it in the same report - "subject to contradiction". (VITAL IMPORTANCE OF BALANCE)

(5) If you have ALL 10 POINTS of Reynolds Test, plus THE PUBLIC INTEREST - then you MAY have QP in making defamatory allegations outright, without quoting somebody protected by AP.

(A) STATUTES:

STATEMENTS HAVING QUALIFIED PRIVILEGE WITHOUT EXPLANATION OR CONTRADICTION (as set out in schedule I the 1996 Defamation Act)


1. A fair and accurate report of proceedings in public of a legislature anywhere in the world.

2. A fair and accurate report of proceedings in public before a court anywhere in the world.

3. A fair and accurate report of proceedings in public of a person appointed to hold a public inquiry by a government or legislature anywhere in the world.

4. A fair and accurate report of proceedings in public anywhere in the world of an international organisation or an international conference.

5. A fair and accurate copy of or extract from any register or other document required by law to be open to public inspection.

6. A notice or advertisement published by or on the authority of a court, or of a judge or officer of a court, anywhere in the world.

7. A fair and accurate copy of or extract from matter published by or on the authority of a government or legislature anywhere in the world.

8. A fair and accurate copy of or extract from matter published anywhere in the world by an international organisation or an international conference.

 

SCHEDULE II - STATEMENTS HAVING QUALIFIED PRIVILEGE IF THE OTHER SIDE OF THE STORY IS GIVEN ALONG SIDE THE DEFAMATORY ALLEGATION (as set out in schedule II of 1996 Defamation Act) ie "Statements privileged subject to explanation or contradiction".


9. - (1) A fair and accurate copy of or extract from a notice or other matter issued for the information of the public by or on behalf of-

(a) a legislature in any member State or the European Parliament;
(b) the government of any member State, or any authority performing governmental functions in any member State or part of a member State, or the European Commission;
(c) an international organisation or international conference.
(2) In this paragraph "governmental functions" includes police functions.

10. A fair and accurate copy of or extract from a document made available by a court in any member State or the European Court of Justice (or any court attached to that court), or by a judge or officer of any such court.

11. - (1) A fair and accurate report of proceedings at any public meeting or sitting in the United Kingdom of-

(a) a local authority or local authority committee;
(b) a justice or justices of the peace acting otherwise than as a court exercising judicial authority;
(c) a commission, tribunal, committee or person appointed for the purposes of any inquiry by any statutory provision, by Her Majesty or by a Minister of the Crown or a Northern Ireland Department;
(d) a person appointed by a local authority to hold a local inquiry in pursuance of any statutory provision;
(e) any other tribunal, board, committee or body constituted by or under, and exercising functions under, any statutory provision.

(all of these above are defined in the Act)

12. - (1) A fair and accurate report of proceedings at any public meeting held in a member State.

(2) In this paragraph a "public meeting" means a meeting bona fide and lawfully held for a lawful purpose and for the furtherance or discussion of a matter of public concern, whether admission to the meeting is general or restricted.

13. - (1) A fair and accurate report of proceedings at a general meeting of a UK public company.

(2) A fair and accurate copy of or extract from any document circulated to members of a UK public company-

(a) by or with the authority of the board of directors of the company,
(b) by the auditors of the company, or
(c) by any member of the company in pursuance of a right conferred by any statutory provision.


(3) A fair and accurate copy of or extract from any document circulated to members of a UK public company which relates to the appointment, resignation, retirement or dismissal of directors of the company.

(5) A fair and accurate report of proceedings at any corresponding meeting of, or copy of or extract from any corresponding document circulated to members of, a public company formed under the law of any of the Channel Islands or the Isle of Man or of another member State.

14. A fair and accurate report of any finding or decision of any of the following descriptions of association, formed in the United Kingdom or another member State, or of any committee or governing body of such an association-

(a) an association formed for the purpose of promoting or encouraging the exercise of or interest in any art, science, religion or learning, and empowered by its constitution to exercise control over or adjudicate on matters of interest or concern to the association, or the actions or conduct of any person subject to such control or adjudication;

(b) an association formed for the purpose of promoting or safeguarding the interests of any trade, business, industry or profession, or of the persons carrying on or engaged in any trade, business, industry or profession, and empowered by its constitution to exercise control over or adjudicate upon matters connected with that trade, business, industry or profession, or the actions or conduct of those persons;

(c) an association formed for the purpose of promoting or safeguarding the interests of a game, sport or pastime to the playing or exercise of which members of the public are invited or admitted, and empowered by its constitution to exercise control over or adjudicate upon persons connected with or taking part in the game, sport or pastime;

(d) an association formed for the purpose of promoting charitable objects or other objects beneficial to the community and empowered by its constitution to exercise control over or to adjudicate on matters of interest or concern to the association, or the actions or conduct of any person subject to such control or adjudication.


15. - (1) A fair and accurate report of, or copy of or extract from, any adjudication, report, statement or notice issued by a body, officer or other person designated for the purposes of this paragraph-

(a) for England and Wales or Northern Ireland, by order of the Lord Chancellor, and
(b) for Scotland, by order of the Secretary of State.
(2) An order under this paragraph shall be made by statutory instrument which shall be subject to annulment in pursuance of a resolution of either House of Parliament.

(B) QP IN COMMON LAW

ie, made up by judges, convention, etc, not by statue.

Qualified privilege in common law rests on the case of Toogood v Spyring (1834) 1 CM&R 181, 193, and onm the idea of "the common convenience and welfare of society", that is, the public interest.

The judge in case said: "The law considers such publication as malicious, unless it is fairly made by a person in the discharge of some public or private duty, whether legal or moral, or in conduct of his own affairs, in matters where his interest is concerned. In such cases the occasion prevents the inference of malice, which draws from unauthorised communications, and affords a qualified defence depending on the absence of actual malice. If fairly warranted by any reasonable occasion or exigency, and honestly made, such communications are protected for the common convenience and welfare of society; and the law has not restricted the right to make them within any narrow limits."

The classic case of common law QP would be a lecturer writing a reference for a student. He would have a duty to tell the truth about teh student even if that truth were per se defamatory. But there would be the protection of QP so long as the reference was written without malice, and there had been steps taken to make sure that it was factually accurate. There are, in other words, various circumstances in civil life where people "have to" make defamatory statements, in fact have a duty to do so.

Another example is that a doctor might say to another doctor that a named patient had a certain disease. This is defamatory per se and might be slander (the defence would be 'justification' if not for QP). But it would be silly for somebody to sue doctors over their own written medical records, so the doctors would have a form of QP. (A journalist would not have a common law QP defence for printing medical records - because it is not in the public interest public interest). In either case the patient would be protected by confidentiality law anyway (that is a seperate subject which we will deal with in subsequent lecture). A doctor who said "I think you look like you have a disease" would have QP even if it turned out that the person did not have the disease.

This common law "duty" to say unwelcome things about people has been developed to extend statutory QP (1996 Act) to the discussion of various matters in the public domain. The common law has been bolstered by the general thrust of the Human Rights act, and for provisions of freedom of expression. Common Law QP has got stronger in recent years (balanced, as it happens, with the privacy provisions of the Human Rights Act - which we will deal with in a later lecture on privacy and confiendtiality.

COMMON LAW QP - THE CLEGG CASE

This was the first significant case where reference to the Human Rights Act was introduced. The result (the actual judgement) is here.

An easy description of the Clegg case and its circumstances can be found here on BBC news online.

What happened was that at a public meeting a group of anti-IRA activists in Northern Ireland it was claimed that a firm of solicitors (Mccartan Turkington Breen) were prosecuting a soldier (Clegg) who was accused of shooting innocent youths, in order to further the aims of the provisional IRA and that the lawyers were in effect ‘helping terrorism’ or were even (by innuendo) terrorist themselves.

When these allegations were reported the lawyers sued for libel. The law firm won £145,000 damages, but the papers appealed and the decision was overturned. On appeal (2000) the lawyers lost, and the papers won, because judges said it was in the public interest that these allegations were made and discussed, so long as the lawyers’ own denials were properly reported (ie the reports were balance, free from factual error, free form malice as with QP in reporting court cases and other events in the schedule of the 1996 defamation act).

There was a lot of interest in the case because:


(a) It was the first case in which the provisions for freedom of expression in the Human Rights acts were used to protect newspapers


(b) It seemed to extend the protection of QP from the courts, through official meetings like those set out in the 1996 defamation act, towards informal events like press conferences, public political meetings and (perhaps) even press releases about meetings like this.

In 2000 Lord Bingham, commenting on the Clegg case (SEE HERE) emphasised and strengthened the meaning of a “public meeting” which might be reported with a type of qualified privilege. Such a gathering is defined in the 1996 act in section 12 as:

(1) A fair and accurate report of proceedings at any public meeting held in a member


(2) In this paragraph a "public meeting" means a meeting bona fide and lawfully held for a lawful purpose and for the furtherance or discussion of a matter of public concern, whether admission to the meeting is general or restricted.

ALBERT REYNOLDS vs SUNDAY TIMES


The Sunday Times said that Irish Prime Minister Albert Reynolds lied to the Irish parliament in order to cover up a child abuse scandal in teh Catholic church. The paper said it believed the allegations were true, but when challenged by Reynolds they could not prove the allegations because (as often must be the case with corruption) there were no witnesses, and no forensic or documentary evidence. Mr Reynolds might have taken the view that all he had to do was deny the allegations and say “where’s your proof”, since in defamation the onus is on the journalist to prove the allegations.


But when the case came to the higher courts (1989), the judges thought the Sunday Times had not only a right, but a “duty” to publish the allegations, since they seemed to be reasonable and it was very much in the public interest that they be discussed. Underlying everything was the (then new) Human Rights Act with its new provision for freedom of expression. More generally, there is an American-type trend towards public officials enjoying less protection from defamation than strictly private citizens, at least in so far as allegations are made about the performance of their public duties.


(Ever since the 1993 Bookbinder/ Derbyshire County Council case, politicians have faced the risk of losing in libel actions, if the REPORTED allegations made against them (even if wrong or debatable) are accurately summarised, are purely about their public duties, and are reported without malice. But if the allegations are about private life, then they still have full protection (as in the John Major vs the New Statesman case. In the Major case the New Statesman said he had an affair and kept a mistress. John Major case here.

THE REYNOLDS CASE and the 10 POINT TEST

Lord Nicholls, the judge in the appeal stage of Albert Reynolds vs Sunday Times (1999), seemed to further define/extend QP-type protection against defamation, so long as the reporter was working without malice (as always with QP – you need lack of malice, accuracy and timeliness), had taken reasonable steps (not reckless) and so long as it was a matter of ‘public interest’ (ie not just a purely private matter).


Lord Nicholls said: ‘The press discharges vital functions as a bloodhound a well as a watchdog. The court should be slow to conclude that a publication was not in the public interest and, therefore, the public had no right to know especially when the information is in the field of political discussion. Any lingering doubts should be resolved in favour of publication.”
However Lord Nicholls emphasised a ‘duty to publish’ if the newspaper or a reporter thought he knew there was something seriously wrong (bloodhound as well as a watchdog).


His ten point test of responsible journalism is well worth dwelling on because it forms a curriculum really for journalism of the highest quality which (quiet rightly) should enjoy a degree of legal protection.


1. The seriousness of the allegation – the more serious the allegation, the more protection will be applied. Trivial allegations which are merely embarrassing would probably not enjoy the protection. Allegations about purely private matters would probably not enjoy protection.

2. The nature of the information and the extent to which the subject matter is a matter of public concern. This follows from schedules I or II of 1996 act - essentially anything related to matters that would be discussed in forums listed in schedule I (ie the discussion of politics, or the content and conduct of trials) would be protected and almost certainly matters that would come up in forums detailed in schedule II would also be covered. Again, allegations of a private nature are excluded (except in so far as they might impact on performance of public or official duties). NB Discussion of what goes on in companies would have more coverage if it is a floated public company with shareholders, or if it was significant in the economy as a whole.


3 . The source of the information. The more authoritative the source, the more you are entitled to report their allegations, even if those allegations can not be proved or even if they turn out to be (to your surprise) incorrect. The test is – “would they have a reason to lie to me?”. So obviously chequebook journalism (where people are paid to make allegations) is not very safe, and would have less protection than allegations made by a responsible person with no axe to grind, and with a reputation for honesty. Also persons with a direct view of event or direct access to information are more to be believed (and therefore your report of what they say more protected) than second hand sources. Sources ‘on the record’ are more protected than anonymous sources. Two sources (or more) saying the same thing independently would of course be much stronger than a single source.

4. The steps taken to verify the information. There must be a reasonable attempt in the time available (see below, point six urgency). The crucial thing is to try and put the allegations to the person being accused in order to get their side of the story. Obviously they will be evasive (especially if they have something to hide) and may give you the ‘run around’ in order to deny you protection under this very point in the ten point test. But you must either get to the person and make the allegation or, at the very least, be able to show a whole log of e-mails and phone calls where you make determined efforts to get their side of the story. A simple “they wouldn’t answer the phone” or “they were unavailable for comment” might not be good enough for this test (it was in fact where the daily Telegraph came unstuck in the Galloway case – see below).

5. The status of the information. You need to check that this is not an old allegation which has previously been denied. If the allegation had been previously dismissed by “an investigation which commands respect” then it would have no protection. For example if the allegation was about a doctor in a hospital. If the allegation had already been through some sort of internal enquiry at a hospital and had been dismissed, you may well lose your protection in repeating it, especially if you overlooked previous dismissal when you were trying to verify the information (see point 3 above – ‘steps taken to verify’).


6. The urgency of the matter.
The judge recognised that news is “a perishable commodity” and that papers must compete to be first with the news. If the matter genuinely is urgent (eg to bring something like corruption to the attention of voters before polling day) then the other checks in the code might be less stringent and might still enjoy protection.

7. Whether comment was sought from the claimant – together with point 4 above and point 8 below, although the judge did say that putting allegations to the claimant was not necessary in every single case, if the case for protection on other counts was strong enough. As a practical point it is always wise to get the other side of the story and have them point out how or why the allegations might be untrue, then incorporate this in your report. Such a statement might also provide you with a ‘consent’ type defence to a libel action.

8. Whether the article contained the gist of the claimant’s side of the story (see above, points 4 and 7

9. The tone of the article. If the angle of a piece is along the lines of allegations of X have raised concerns… this would probably more protected than a straightforward assertion that the allegations are fact. It is always important to attribute the allegations to a named source (‘on the record’) if possible. If the source is not named there must be a genuine and obvious reason for this (eg they fear getting the sack, or being attacked). But with ‘protected sources’ and ‘off the record’ there is always the separate (and growing) legal danger of action for breach of confidence.

10. The circumstances of the publication, including the timing. The allegations should be brought to public attention as quickly as possible. They should not be ‘saved up’ for commercial motives by the paper or broadcaster. This is similar to the need to publish/broadcast quickly in ordinary QP of court and parliamentary reports.

THE LOUTCHANSKY CASE


In this case (which is also of interest because of the separate problem of ‘internet libel’ – ie each time an article is loaded from a newspaper online archive it constitutes a fresh instance of ‘publication’ and can thus activate a libel action) the judge worked his way methodically through all ten points of the Reynolds ‘responsible journalism’ test. It is very useful to follow his points.

 

THE GALLOWAY CASE (a Reynolds defence fails)


The Daily Telegraph attempted a Reynolds defence to an action from George Galloway after the paper made very serious defamatory allegations against him, for which there was no defence of JUSTIFICATION (true and can be proves) or COMMENT or QP in the sense that it was reporting ‘second hand’ what had been said in court. Instead the paper was quoting a source it said it trusted.
The Telegraph lost the case because the journalist failed the ’10 point test’ – in this case mainly because, despite a quick call to Galloway, the paper did not put all its allegations to Galloway for him to deny before they published the information.


If the reporter had shown Galloway all the ‘secret documents’ ity had been given, and really given Galloway a chance to persuade the reporter they were not true, then there might not have been a legal action.

Commentary on the Galloway case and Lord Nicholls’ Ten Point Test


ANOTHER WORRYING REYNOLDS FAILURE –Mohammed Abdul Latif Jameel vs Wall Street Journal (Feb 2005)

The paper thought it had reasonable grounds for airing allegations from what it believed to be a good source that a certain Saudi Arabian businessman was involved in financing terrorism. The report could not prove the allegation, but believed that she had a Reynolds “duty” to report that the allegations were being taken seriously by various important and responsible people. But the allegations could not be proved, and therefore not defended with “justification” so she relied on a Reynolds defence. In her own view (and the view of many commentators) she though she had stayed within the 10 point test. But Lord Phillips on appeal did not agree. The Wall Street Journal loses.

But the Wall Street Journal appealed.

Lawyers for the PPA note:

The Lords held that Reynolds had been interpreted too strictly in the past: the 10 criteria, including steps taken to verify the information and the tone of the article, were pointers as opposed to hurdles for the media.

The result of the Jameel case is that the media have much more freedom when reporting matters of public interest, where it may not be possible to subsequently prove the truth of the allegations, provided that they act reasonably and in the public interest.

There is no legal definition of 'the public interest' so rely on the definition given in the PCC code of conduct - the main points being

(1) exposing crime

(2) exposing health risk to the community

(3) exposing lying and hypocrisy in public life

What the PCC actually says about the public interest is lengthy. Here it is:

interest

There may be exceptions to the clauses marked * where they can be demonstrated to be in the public interest.

1. The public interest includes, but is not confined to:
i) Detecting or exposing crime or serious impropriety.
ii) Protecting public health and safety.
iii) Preventing the public from being misled by an action or statement of an individual or organisation.

2. There is a public interest in freedom of expression itself. [CH adds - this has the nacking of the law, section 10 of the Human Rights Act]

3. Whenever the public interest is invoked, the PCC will require editors to demonstrate fully how the public interest was served.

4. The PCC will consider the extent to which material is already in the public domain, or will become so.

5. In cases involving children under 16, editors must demonstrate an exceptional public interest to over-ride the normally paramount interest of the child.

 

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