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Watt v. Longsdon

King’s Bench
[1930] I. K.B. 130


Facts

Watt (plaintiff) was managing director at Casablanca, Morocco of a British oil company. Longsdon (defendant) was director of the company. Watt brought suit against Longsdon for three separate counts of defamation. First, in April 1928, Browne, the company’s manager in Casablanca, wrote a letter to Longsdon alleging Watt failed to pay a liquor bill and had sexual relations with a mistress. In May 1928, Longsdon showed the letter to Singer, chairman of the board of directors of the company. This is the first alleged defamatory act. Next, Longsdon wrote a reply letter to Browne expressing his own negative views about Watt and requesting Browne obtain sworn statements as to the letter’s contents. This is the second alleged defamatory act. Finally, without receiving sworn statements from Browne, Longsdon showed Browne’s letter to Watt’s wife, and she filed for divorce. The showing of the letter to Watt’s wife is the third alleged defamatory act. Although Longsdon did not defend the truth of the letters, the trial judge issued judgment for Longsdon on the ground that the letters were privileged. Watt appealed.

Rule of Law

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Issue

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Holding and Reasoning (Scrutton, L.J.)

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Dissent (Greer, L.J.)

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