White v Express Newspapers; Callaghan v Express Newspapers [2014] EWHC 657 (QB), [2014] All ER (D) 177 (Mar)
In actions brought by a well-known snooker player and a person said to have colluded with him, it was held that the governing principle in determining libel was reasonableness. It was established law that a sting of a libel might be capable of meaning that a claimant (level 1) had in fact committed some serious act, such as murder. Alternatively, it might be suggested that the words meant that (level 2) there were reasonable grounds to suspect that he/she had committed such an act. A third possibility was that they might mean that (level 3) there were grounds for investigating whether he/she had been responsible for such an act. It did not follow that all words complained of had to be fitted into one or other of these categories. There might be meanings which were less serious than level 3, but if there were, then a dispute might arise as to whether such lower meanings were defamatory at all. The court was not bound to choose between the contentions of
