McManus v Beckham [2002] 1 WLR 2982

Defendant entered Plaintiff’s celebrity memorabilia shop and claimed to customers in the shop that the memorabilia was faked.

This story was repeated in the press and Plaintiff sued for defamation. Defendant sought to strike out claims based on newspaper repetitions as being to remote.

CA denied the striking out application, finding for Plaintiff.

• It held that if Defendant was actually (or a reasonable person would have been) aware that what he said or did was likely to be reported and that if he slandered someone that slander was likely to be repeated, there was no injustice in him being held responsible for the damage that the slander caused by means of that publication.

• A new publication doesn’t automatically equal Novus Actus Interveniens (NAI).