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Lachaux v Independent Print Ltd [2019] UKSC 27

By Oxbridge Law TeamUpdated 08/08/2023 01:10

Judgement for the case Lachaux v Independent Print Ltd

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Tort Law Notes

Tort Law

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  • The law makes a clear distinction between two types of defamation, namely: (1) actionable per se, which includes all libels and two specific types of slander (formerly four), and (2) defamation actionable only with proof of special damage, which encompasses all other slander. For the latter category, pecuniary loss must be proven.
  • A statement that was previously considered defamatory based on its inherent tendency is not legally actionable unless it has caused or is likely to cause "serious" harm.
  • The phrase "has caused" pertains to the historical consequences of the publication, which must be determined based on the actual impact of the statement. This involves a factual assessment that considers both the inherent tendency of the words and their actual impact on the recipients.


  • The claimant, Bruno Lachaux, initiated divorce proceedings in the United Arab Emirates (UAE) courts and sought custody of his son, Louis, after his marriage with Afsana broke down.
  • Afsana went into hiding with Louis, leading to a custody battle in which the UAE court awarded custody to Mr. Lachaux. Subsequently, British newspapers published articles alleging Mr. Lachaux's abusive behaviour towards Afsana and manipulative actions during the custody proceedings.
  • Mr. Lachaux filed libel actions against the newspapers, and the courts assessed whether the publications met the "serious harm" test under the 2013 Act. 


  • This case clarifies the burden of proof for claimants, emphasising that they must show evidence of serious harm to their reputation caused by defamatory statements. The ruling acknowledges that serious harm can be inferred from the inherent tendency of the words used in the publications to cause damage to the claimant's reputation.
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