D cast aspersions about the propriety of P’s (an local council) financial dealings, and P sued for libel. HL held that no organs of government may bring an action in libel.
Lord Keith: Since the mere threat of civil actions is enough to have a “chilling effect”, stopping the creation of certain materials that would otherwise be published, and given the importance of allowing people to criticise the government, it would be against the public interest to allow governmental bodies to sue for libel. Secondly, it makes no sense to talk about a council having a reputation per se. The thing that has the reputation will be the political party controlling it (No- some councils have a reputation for being good, others do not).