P’s waxwork effigy was placed in a room with effigies of murderers entitled “chamber of horrors” on account of his being accused of murdering a person. However he had been found not guilty and sued D for defamation. CA said that there was defamation arising from the effigy’s placement and carried a defamatory meaning.
Lopes LJ: “libels are generally in writing …but this is not necessary; the defamatory matter may be conveyed in some other permanent form. For instance, a statue, caricature, effigy, chalk marks on a wall, signs or pictures may constitute a libel.
