Milne v Express Newspapers Ltd

 D made a false claim about P and offered to make amends under s.2 of Defamation Act 1996 which P rejected, so that D claimed a defence under s.4(2) of the act. P sought to rebut this defence by saying that D had reason to believe that facts to be false so that s.4(3) applied. CA found for D, saying that s.4(3) only applied where D knew the facts were false, NOT that he ought to have known of the facts.