Slipper v BBC [1991] 1 QB 283

Court of Appeal

Basic Facts: D made a film depicting C as an incompetent buffoon. C sued for defamation due to both the pre-release press and the film's broadcast.

Issue for the Court: Does repetition of defamatory statements increase damages, and can D be liable for third-party repetitions?

Held: the court held that the D can be liable for any re-publication of the defamatory material as long as it was reasonably foreseeable

• Stocker LJ:

• Repetition of a libel may be considered a natural consequence of the original publication if foreseeable.

• D can be liable for repetition even if not directly authorized.

• Bingham LJ:

• Defamatory statements tend to spread beyond the original publication.

• Damages can include foreseeable and provable effects of the defamatory publication.

• Slade LJ:

• Unauthorized repetition of libel may not always be a novus actus interveniens.

• On certain facts, repetition may be seen as a probable consequence of the original publication.