McManus v Beckham [2002] EWCA Civ 939

Court of Appeal 

Basic Facts: Victoria Beckham made defamatory comments about autographs in a memorabilia store, which were then widely reported by the press, causing a downturn in the store's business. The store sued for defamation. 

Issue: Can the defendant be held liable for unauthorised repetitions of their defamatory statements? 

Held: The defendant was held to be liable for her statement and the repeated words in the press, because the claimant suffered a measurable economic loss and it was a foreseeable that her words would be published (due to her status) and therefore damage is likely to occur.

• Waller LJ : Appeal allowed. The defendant can be liable for damage caused by unauthorised repetition of defamatory statements if it was a natural consequence of the original statement or if the defendant should have foreseen it. 

• Laws LJ : Liability depends on whether a reasonable person in the defendant's position could foresee that the statement would be repeated and cause damage.