D showed a programme portraying P as an incompetent policeman. Reviews of the programme in newspapers meant that the claim was repeated many times and P sued D for each repetition of the claim as a separate cause of damages. D sought to have all but the claim based on the TV programme itself struck out. CA found for P, REJECTING the argument that D could not be liable for the repetition by any TP’s who was not their agent nor authorised to do so nor intended to do so. The rules on third party repetition are the normal ones of novus actus interveniens, and on the facts of each case.
Stocker LJ: This is a question of remoteness of damages, depending on whether the damage was “foreseeable or a natural and probable consequence of the invitation to review that such reviews would include the sting of libel”.
Slade LJ: If a repetition is “reasonably foreseeable” then it is not too remote for it to be sued upon as damage caused by D.