Reynolds v. Times Newspapers Ltd.
United Kingdom House of Lords
[2001] 2 AC 127, [1999] 4 All ER 609, [1999] 3 WLR 1010 (1999)
- Written by Liz Nakamura, JD
Facts
Albert Reynolds (plaintiff), the former Prime Minister of Ireland, resigned after a political controversy in 1994. Times Newspapers Ltd. (TNL) (defendant) published an article in its Britain-based Sunday Times about Reynolds’s resignation, including allegations that Reynolds had lied to the Irish Parliament; the article omitted Reynolds’s response to the allegations. Reynolds filed a defamation action against TNL, alleging that the article was libelous and that the allegations were false. TNL countered, arguing that its publication of the article was entitled to qualified privilege against defamation liability because the article’s subject matter involved political information and the article had been published in good faith. The trial court found that the allegations were false but that TNL had not acted with malice. The trial court further held that TNL could not raise the defense of qualified privilege simply because the article involved political commentary and information. The trial court awarded one penny in damages. Both Reynolds and TNL appealed. On appeal, the appellate court affirmed the trial court’s ruling on the inapplicability of qualified immunity but ordered a new trial based on improper jury instructions. TNL appealed to the House of Lords.
Rule of Law
Issue
Holding and Reasoning (Lord Nicholls of Birkenhead)
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