In defamation cases, the Court must identify the natural and ordinary meaning of the words complained of, including any inferential meaning that a reasonable reader would draw. In the recent case of Ranaie v Warland [2025] EWHC 3320, the parties agreed to a Trial of Preliminary Issues to first determine:
(1) the natural and ordinary meaning of the words; and
(2) whether the opinion indicated its basis.
Background
The Claimant and the Defendant were next-door neighbours who fell out. In March 2023, the Defendant sent an email to the Chief People Officer of the Claimant’s company, where the Claimant worked as the Chief Financial Officer. The Claimant alleged that the contents of the email were defamatory. In April 2023, the Claimant was dismissed by her company with immediate effect and given a payment in lieu of notice. The Claimant claimed that her dismissal was the direct consequence of the email. The Claimant sought damages and an injunction against the Defendant.
The Defendant denied that the email was defamatory, arguing that parts of it were opinion relying on the defence of honest opinion, whilst accepting that imputations of tortious/criminal misconduct would be defamatory at common law.
Decision
The Court held that:
- The natural and ordinary meaning of the email was that:-
- The Claimant had:-
- Repeatedly trespassed on the Defendant’s property without due cause;
- Caused criminal damage to the Defendant’s roof; and
- Engaged in ongoing harassment of the Defendant and his spouse;
- There is a pending criminal investigation into the Claimant’s actions for harassment, triggered by a complaint made by the Defendant and his wife, through which the Defendant and his wife are seeking relief, including a restraining order; and
- There are pending civil proceedings that have been brought by the Defendant and his wife against the Claimant for harassment, in which the Defendant and his wife are seeking injunctive relief and a restraining order to prevent the Claimant from continuing to harass them;
- The Claimant had:-
- The statements were Chase level 1 – direct allegations of guilt rather than mere suspicion/grounds for investigation;
- There was an inferential statement of opinion: ‘Unless she is provided with appropriate support and assistance, it is likely that the Claimant’s behaviour will be increasingly erratic, and that she will behave in the future in a way that will cause severe stress and anxiety for her employer and work colleagues, and for the Defendant and his wife’; and
- The statements of fact and opinion are both defamatory of the Claimant at common law.
How can we help?
Ronny Tang is an Associate in our expert Dispute Resolution team, specialising in defamation claims, contentious probate and inheritance claims, Trusts of Land and Appointment of Trustees Act 1996 claims, Equality Act 2010 claims and Protection From Harassment 1997 claims.
If you need any advice concerning the subject discussed in this article, please do not hesitate to contact Ronny or another member of the team in Derby, Leicester, or Nottingham on 0800 024 1976 or via our online enquiry form.
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