Lewis v Daily Telegraph [1964] AC 234

House of Lords 

Basic Facts: The defendant published reports suggesting the police were investigating the plaintiff’s business. The plaintiff denied the reports and sued, claiming the implication was that they were being investigated for fraud. The defendant admitted the statements were libellous but argued they did not carry the defamatory meaning claimed by the plaintiff. 

Issue: What constitutes a libellous statement? 

Held : Appeal dismissed. a new trial of each action should be ordered

• Lord Hodson: There are separate causes of action for the ordinary meaning of words and "true" innuendo (based on extraneous facts), but not for "false innuendo." 

• Lord Morris (dissenting): The meaning of the words depends on what a reasonable reader would infer, especially in light of how a reasonable newspaper would report a police inquiry. 

Key Issues :

• Libel and Inference: Defamatory "sting" may lie in the words themselves or in the inference drawn by an ordinary person. The test is whether an ordinary reasonable person would understand the words to expose the plaintiff to hatred, contempt, or ridicule.