D wrote series of articles parodying style of C, a Conservative MP famous for writing diaries. Articles had headings such as ‘Alan Clark’s Secret Political Diaries’. Underneath title, D’s name was indicated in capital letters as author. C sued for false attribution under s.84. Held:
· Relevant question is whether a reasonable viewer of work would believe C was author.
· On facts, headings of articles gave rise to a clear false attribution.
· Statement in capital as to actual author was insufficient to counteract this false attribution.