Law of Defamation

Wednesday, January 31, 2007

 

UK Defamation Act 1996 and Political Libels

The Defamation Act 1996 and Political Libels
[1997] Public Law 113
by Andrew Sharland, Barrister, and Ian Loveland, Brunel University


Neil Hamilton's libel action against The Guardian promised to be the most spectacular political event of 1996. The Guardian had run several articles accusing Hamilton of receiving large sums of money, which were not declared in the Commons' Register of Members' Interests, from various commercial sources. Hamilton claimed the stories were defamatory, and having resigned as a Minister in order to clear his name, initiated libel proceedings. The Guardian pleaded justification as its defence. At the trial, in July 1995, May J. ordered a stay of the proceedings.1 He considered himself bound to do so by a recent Privy Council decision, Prebble v Television New Zealand Ltd.2

Prebble was a libel action brought by a government Minister in New Zealand. The defendant wished to refer to statements made by the plaintiff in the New Zealand legislature as part of its defence. The New Zealand Court of Appeal considered that any such reference was precluded by provisions of New Zealand's Legislature Act 1908, which were textually identical to Article 9 of the English Bill of Rights-namely that "freedom of speech and debate and proceedings in Parliament ought not to be impeached or questioned in any court or place out of Parliament". The Court of Appeal concluded that NZTV would thus be unable to mount an effective defence to the claim. Consequently, the interests of justice demanded that the action be stayed. On further appeal, the judicial Committee of the Privy Council approved the New Zealand Court of Appeal's interpretation of Article 9 insofar as it affected New Zealand. In Hamilton, May J. held that Article 9 required the same result to be reached in England.

This article analyses both the reasoning employed by the Privy Council, and the arguments subsequently made in the Commons and the Lords in respect of a clause (eventually enacted as section 13 of the Defamation Act 1996) in the Defamation Bill 1996. The clause was intended to reverse May J.'s importation of Prebble into British law. We suggest that Prebble and the relevant provision of the Defamation Act 1996 are poorly conceived as a matter both of law and of Politics, and we offer an alternative solution to the Prebble scenario which is rather more sensitive to the constitutional issues at stake.

Prebble - the Privy Council's reasoning

At first instance, NZTV's defence to Prebble's action was simply that its statements were true. Prebble applied to have those parts of the justification defence relating to his speeches in the legislature struck out. He was initially successful. However the New Zealand Court of Appeal 3 concluded that if such evidence was inadmissible, the proceedings would have to be stayed, as NZTV could not mount a proper defence.

Lord Browne-Wilkinson, in the Privy Council, suggested that Prebble brought several competing interests before the court;

[This] case-illustrate[s] how public policy, or human rights, issues can conflict. There are three such issues in play. . . : first the need to ensure that the legislature can exercise its powers freely on behalf of its electors, with access to all relevant information: second the need to protect freedom of speech generally; third the interests of justice in ensuring that all relevant evidence is available to the Courts. Their Lordships are of the view that the law has long been settled that, of these three public interests, the first must prevail.4

The reasoning underlying this conclusion rested on two foundations, which Lord Browne-Wilkinson termed the "basic concept" and the "wider principle" inherent in Article 9. The "basic concept" is that an M.P must be able to say anything via a proceeding in Parliament without fear that the comments might subsequently be "held against him" in any legal action. A natural interpretation of the concept might imply that it reached only to speech which was itself the subject of the suit, for example a criminal prosecution for incitement or sedition, or a civil defamation action. However Prebble established that the immunity is wider than that. It not clear why this is the case. Having a statement in Parliament invoked as evidence in respect of a suit whose substance derives from words or actions which are not proceedings in Parliament might, it is true, inconvenience or embarrass an M.P., but this is not a serious detriment. Nor would the use of such evidence in court proceedings necessarily require the M.P. to be present in court or to attend at inconvenient times. Furthermore, any evidence the M.P. might give in court relating to the parliamentary proceedings under discussion would itself enjoy the normal immunity from further suit. M.Ps do not enjoy any general dispensation from appearing as witnesses in litigation,5 and one can only assume that Parliament has yet to regard this prospect as a serious impediment to the Houses' efficient dispatch of their work.

Even if one accepts Lord Browne-Wilkinson's conclusion that the first of the three "interests" should be dominant, it does not follow that the court should afford parliamentary proceedings absolute legal immunity. Indeed, Lord Browne-Wilkinson's own formulation seems to contain two qualifications to any such conclusion. The first is that legislators' activities derive their legitimacy from the assumption that they are undertaken "on behalf" of their electors. The second is that such activities are pursued on the basis of "relevant" information. But legislators may, deliberately or unwittingly- act against the electorate's interests, and legislative debate and decision-making might be affected by reliance on "irrelevant" information. Prebble appears to indicate that evidence of such matters cannot be allowed to affect the outcome of a case.

Lord Browne-Wilkinson derived his "wider principle" from the separation of powers;

[T]he courts and Parliament are both astute to recognise their respective constitutional roles. So far as the Courts are concerned they will not allow any challenge to be made to what is said or done within the walls of Parliament in performance of its legislative functions and protection of its established privileges.6

To hear these words from the judge who delivered the majority opinion in Pepper v Hart 7 is rather puzzling. The ratio of Pepper was of course that the courts may now refer to Hansard as an aid to statutory interpretation in certain circumstances. Given that the latter function does not "challenge" House proceedings, it is not clear why the use of Hansard as evidence in a libel action would do so.

The Defamation Act 1996 s.13

What is now section 13 of the Defamation Act 1996 first surfaced as a proposed amendment to the Bill at the Lords Committee stage by Lord Hoffmann. It seems only four members of the upper House were present at the time, and the measure was not fully discussed in the Lords until the bill reached its third reading.8 The introduction of the amendment was surrounded by some confusion. Lord Hoffmann offered his proposal so that the Lords could discuss the desirability of remedying what he perceived as an injustice which Mr Hamilton had suffered: he had no particular commitment to vote for the amendment himself. The nub of the proposal was that an individual M.P. should be given the power to permit House proceedings to be used as evidence in any libel litigation in which he or she was involved.

Lord Hoffmann suggested that it was; "unjust that [Mr Hamilton] should not be able to put the matter before a judge and jury, like any other citizen who feels that his integrity has been publicly defamed".9 He rejected as "deceptive" the suggestion that Prebble merely created a "symmetry" between the M.P. and the citizen-namely that if Article 9 gave M.Ps absolute immunity for defamatory statements made in either House about companies or private individuals, it should also prevent M.Ps suing such companies or individuals for defamation in circumstances where House proceedings formed part of the defence. Lord Hoffmann saw a profound public interest in the first limb of this equation, and none at all in the second. Lord Hoffmann alluded to several counter-arguments against his proposal, each of which was elaborated by other members of the House. Lord Simon of Glaisdale suggested that, irrespective of the merits of the proposal, the process through which the amendment had been introduced was precipitate. So significant an amendment to the Bill of Rights of 1689 should more properly be the subject of investigation by a joint committee of both Houses. He also saw a profound substantive difficulty with the proposal. The immunity privilege in Article 9 had traditionally been regarded as belonging to each House as a collectivity: Lord Hoffmann's amendment would in effect enable an individual M.P to override either House's collective view. Quite what would happen if an individual sought to invoke the power, and the House concerned wished to prevent the evidence being put before the court, was far from clear.10 Lord Ewing of Kirkford offered a further objection. His experience in the Commons had led him to conclude that M.Ps themselves readily abused their protection from defamation suits by making unsupportable accusations in the House. He suggested that to leave the victims of such defamation without a remedy, while enhancing the remedies available to M.Ps was not an appropriate course for Parliament to follow.

Lord Lester of Herne Hill advanced the most coherent and comprehensive objection to the amendment. He observed that it was by no means beyond argument that Hamilton (and presumably by implication Prebble) was wrongly decided, and regretted that Neil Hamilton had not challenged May J.'s ruling before the Court of Appeal. There is much force in this argument, to which we shall return below. The amendment also had technical flaws: what would happen for example in litigation involving two or more M.Ps, where one agreed to waive privilege and the others declined to do so. In such circumstances, would Article 9 trump the new Defamation Act? Or vice-versa? Lord Lester was also the only member of the House to dwell on the implications the amendment would have for the freedom of the press, and thence on the electorate's access to critical information about M.Ps and Ministers. He observed that press uncertainty about whether an M.P. would waive privilege might "chill" the dissemination of critical news stories.

Lord Lester's concerns failed to sway the majority of his colleagues. The government had maintained that Lord Hoffmann's amendment, while introduced into a government bill, would not be whipped. Members could vote on it as they wished. Yet over 200 peers voted on the amendment at third reading-an extraordinarily high number. The vote was 157 in favour and 57 against. Lord Hoffmann abstained.

The suspicion that a de facto if not de jure whip was operating was reinforced by events in the Commons.11 The amendment was bundled through at second reading. At third reading,12 the Labour party decided to oppose the amendment. The party's Legal Affairs spokesman, Paul Boateng, moved a further amendment which would have given the House collectively, rather than an individual M.P., the power to waive privilege in cases such as Mr Hamilton's.

Several members from both parties suggested that the issue was being unnecessarily rushed. Lord Simon's proposal for a joint committee of both Houses to investigate the matter received considerable support-but not from the government.

Some members of the Commons also expressed concern that the Hoffmann amendment would require the courts to determine exactly what was meant by "proceedings in Parliament". Definition of this term has long been a source of controversy between the Houses and the courts, and the Commons has consistently expressed the opinion that the meaning of the term (notwithstanding its presence in a statute) is a matter for M.Ps, not for the court.13 That position would of course be difficult to sustain - at least in respect of defamation actions - if the House now approved a Bill which when enacted would force the courts to address the question.

Mr Boateng pointed to a further irony in this regard. The third reading debate was immediately preceded by a statement from the Secretary of State for Social Security in response to a recent Court of Appeal decision on asylum seekers and social security benefits.14 The court had quashed regulations issued by the Secretary of State which denied benefits to asylum seekers-remarking along the way that such a policy seemed "uncivilised". Observers in the House on June 24, 15 were treated to the unedifying spectacle of backbench Conservative M.Ps indulging in apoplectic attacks against the "undemocratic" judiciary. The gist of their complaints seemed to be the assumption that as long as a Minister's interpretation of a statute enjoyed the support of a majority of Members of the Commons, the courts had no business to challenge it.

Such constitutional illiteracy would in general be laughable, were not the M.Ps' ready equation of a Commons majority with Parliament so worrying. But in respect of Article 9 at least, the equation is not so absurd. Article 9 is, and always has been, a statutory provision, yet the Commons has always denied the courts' capacity to determine its meaning. It seems entirely likely that section 13 of the Defamation Act will prompt just the same dispute. The Leader of the House (Tony Newton) and the Attorney-General (Sir Nicholas Lyell) did little to allay this concern. Paul Boateng, echoing Lord Lester's concern in the Lords, had asked in the House if the amendment would enable an individual member to place Select Committee reports or discussions in which he or she had participated before the courts, even if the committee in question opposed such action. The Act itself offers little but confusion on this point. In its final form, section 13(1) allows an individual to waive privilege "so far as it concerns him", while section 13(3) states that; "The waiver by one person of that protection [i.e. of Article 9] does not affect its operation in relation to another person who has not waived it".

These two provisions seem to offer us the prospect of one M.P. waiving privilege in respect of an answer he or she may have given to a question in Committee, and of the questioner refusing to waive his or her privilege. The "evidence" thus brought before the court might very well be meaningless. This result would seem to be required by a literal reading of section 13(3), but a court which was predisposed to apply the mischief rule (with Hamilton v The Guardian being the mischief in mind) to the sub-section could plausibly reach a different conclusion.

Dale Campbell-Savours M.P. elaborated upon Mr Boateng's point in the House by asking if an individual M.P.'s proposed statutory right to waive privilege could also extend to documents which a committee had examined as part of its deliberations.16 The Hoffmann amendment (now section 13(2)) applied the waiver to "evidence", "questions asked", "statements", "submissions", and "findings" - labels which could readily be thought to reach Mr Campbell-Savour's "documents". This raises, inter alia, the question whether an M.P. qua libel litigant could rely on such a document (which made allegations concerning the behaviour of another M.P.) against the Committee's wishes - a point which demanded an answer as to the intended reach of section 13(3).

The leader of the House (Mr Newton) and the Attorney-General addressed a rather different point - namely whether a defendant newspaper in a future Hamilton v The Guardian scenario would be able via section 13 to extract such documents from a House committee. For rather than addressing the terms of the then clause 13(3) itself, Mr Newton (relaying the Attorney-General's advice) replied to Mr Campbell-Savours by referring to the ordinary rules of discovery, which of course only regulate the relationship between the parties to the action.

The Attorney-General argued that "the other party" in a libel action would not be able to use such information, since the committee, rather than the Member herself, would "possess" the documentation in question.17 In a limited sense this view is correct. R.S.C. Ord. 24, r. 2 does indeed restrict discovery to documents which are or have been in the "possession, custody or power" of the parties to the litigation. But in cases where House proceedings have culminated in published reports or are broadcast on television and radio, this notion of "possession" raises immediate problems. If the documentation in question has been published, or parts of it have been read verbatim or paraphrased into published or broadcast House proceedings, rules of discovery would not prevent either party to a libel action relying on it in litigation - no discovery would be necessary.

In respect of unpublished proceedings, the Attorney-General's invocation of R.S.C. Ord. 24, is defensible from the narrow, legal perspective. From a broader political perspective the notion that the contents and product of legislative debate or committee inquiry is the "possession" of the House rather than of the public might be considered objectionable.

In respect of published proceedings, the question that Mr Campbell-Savours was putting was whether the House or one of its committees could prevent the use in a libel action of House proceedings which litigants could obtain without recourse to discovery. The text of the Act does not offer an unambiguous answer to this question. And should a court at some future date follow the path opened up by Pepper v Hart and refer to Hansard for clarification as to the intentions of the framers of section 13, it is unlikely to find enlightenment.

The House of Commons nevertheless favoured the Hoffmann amendment. The prevailing mood on the Conservative benches was best illustrated by Sir Peter Tapsell, who described the amendment as saving M.Ps from "persecution . . . from what many people regard as an over-mighty press that is owned, for the most part, by foreigners".18 Facing so obviously unreceptive Conservative members, Mr. Boateng withdrew the Labour amendment. The Hoffmann amendment was approved, and the bill received the Royal Assent in the autumn.

Rupert Allason was the first M.P. to take advantage of section 13, waiving the House's privilege in order to continue a libel action against the Mirror Group. Hamilton followed suit in his action against The Guardian. He then decided not to proceed with the litigation when it appeared that he and his co-plaintiff, the lobbyist Ian Greer, would offer the court contradictory accounts of their financial relationship. But the statutory legacy the Hamilton case has bequeathed exacerbates rather than cures the unfortunate consequences for freedom of political speech in this country that the Prebble decision created.

Was Prebble wrongly decided?

A rather more sophisticated Australasian solution to the Prebble problem was offered by Hunt J.'s 1986 decision in R v Murphy,19 in which the New South Wales Supreme Court was faced with the question of whether the N.S.W equivalent of Article 9 precluded the use of legislative proceedings as evidence in a libel suit.

Hunt J.'s reasoning and conclusion in Murphy stand in marked contrast to that deployed in Prebble. His reading of British constitutional history led him to conclude that Article 9 was enacted to give absolute protection to M.Ps only against legal actions launched by the Crown. Where the dispute was between an MT and an individual citizen Article 9 had to bear a very different meaning;

The proper interpretation to be placed upon Article 9 . . . must be one which recognises the freedom given by the common law to every citizen to express publicly his honest opinion concerning the conduct of members of Parliament, no matter to what extent that opinion may impeach or question that conduct.20

Hunt J. recognised the dissemination of "honest" speech on "political" matters as the common law's21 most important consideration when faced with a defamation action. His reasoning suggests that citizens (or the press) do not have effective freedom of speech if they are denied the opportunity to establish that their criticism of an M.P.'s behaviour or speech was honest when they are threatened with a defamation action. But literal interpretation of Article 9 would have precisely that effect in any such litigation which required examination of House proceedings.

Hunt J.'s historical perspective was buttressed by a contemporary political argument. The above quoted reference to the common law's protection of the individual citizen's freedom of speech was not invoked just to support individual rights: it also had a collective dimension. Individuals qua members of the electorate had a shared interest in the "the ascertainment of truth" .22 This function, in the event of libel actions between citizens, was generally discharged by the courts. Interpreting Article 9 as imposing an absolute bar on the use of parliamentary material as evidence in defamation actions would be a thoroughly anti-democratic position for the courts to adopt because it frustrated the search for "truth" about political matters. If the evidence was necessary to resolve a defamation claim centering on an M.P's behaviour, it should be examined by the court.

Hunt J.'s argument assumes that statutory and common law provisions regulating political speech should be construed in a way which maximises citizens' collective capacity to reach informed decisions about the acceptability of legislators' behaviour. Conclusions based on inadequate or false information frustrate that purpose and so corrupt the basis of consent to government. Murphy appears to assume that it is the interest of the audience - namely potential voters rather than of the individual M.P. or the House acting collectively that should weigh most heavily in the court's mind when interpreting Article 9. This point was barely acknowledged by the Privy Council in Prebble, and with the notable exception of Lord Lester, was altogether ignored by those who spoke in each House on the Hoffmann amendment.

One need not be blessed with atypically heightened powers of political perception to see the audience interest in having the Hamilton saga resolved by a court. If The Guardian had told lies about Mr Hamilton, Guardian readers might well have decided that they should in future seek their political commentary elsewhere, and wavering Conservative voters worried about Hamilton's integrity might have concluded that their doubts were falsely based. Had the claims been proven true, such voters might have found their electoral sympathies moving in a different direction, and Guardian readers would have been reassured that the paper's political coverage is likely to be soundly based in fact.

Lord Lester had alluded briefly in his speech to US. Supreme Court case law which had rejected arguments favouring an absolutist interpretation of the "speech and debate clause" in the U.S. constitution, a clause lifted verbatim from the English Bill of Rights. There is indeed now an extensive body of case law addressing the relationship between the "speech and debate clause" and the First Amendment's guarantees of freedom of speech and the press,23 one strand of which suggests that legislative privilege is an insufficiently important factor to justify the automatic exclusion of legislative proceedings as evidence in defamation suits. There is even some authority for the proposition that a legislator's speech in the House or Senate may be the subject of a defamation action if the speaker has knowingly or recklessly disseminated lies.24

Given that the House of Lords relied so heavily on US. principles to recast our own political libel laws in Derbyshire v Times Newspapers,25 it is regrettable that our Court of Appeal was not presented with an opportunity to consider the American law on the speech and debate clause in the Hamilton case. Yet the opportunity has not disappeared altogether. Having completed his third reading attack on the foreign-owned media (which one assumes, ironically, excludes The Guardian but includes The Times, The Telegraph and The Independent), Sir Peter Tapsell implored the house to "bring up to date the ideas that led to the Bill of Rights".26 As we have indicated above, we doubt that section 13 achieves that laudable objective.

Conclusion - how should Prebble have been decided?

The chief objection to Prebble is that it ignored the audience interest in having courts resolve political libel actions. The judgment made it impossible for M.Ps to pursue such actions if they involved proceedings in Parliament. Section 13 has not removed that objection - rather it places the audience interest at the mercy of an individual M.P's calculations as to the viability of his or her suit.

But this judicial and now legislative indifference to the electorate's interest in such litigation has a second dimension, compared to which the issue apparently resolved by section 13 is really of limited significance. The second dimension poses a simple question: given that individual M.Ps now seem to be able to pick and choose whether or not to allow parliamentary proceedings to be used as evidence in libel suits, what substantive barriers should the common law place in their path when they initiate such suits in respect of criticism of their political beliefs of behaviour?

Mr Hamilton, had he not withdrawn his action against The Guardian, would have expected our libel laws to treat him as if he were a private citizen. Damage to his reputation would have been presumed merely by the publication of the defamatory story. The burden would then have fallen on The Guardian to prove the truth of any factual claims it made if it was to escape liability. Recent Court of Appeal and ECHR decisions have indicated that all libel plaintiffs may now expect to receive rather lower damages than they have in the past,27 but these developments have no specific bearing on the obstacles plaintiffs must surmount to win their actions.

The US.'s "Sullivan defence"28 has long since provided the primary point of focus for commentators advocating reform of our political libel laws. The Sullivan defence is a supra-legislative construct, derived from the First Amendment. It requires politicians to prove both the falsity of any factual claims made against them and that the disseminator knew the claims were false or was reckless in failing to investigate their accuracy. The test makes it difficult-but not impossible-for a politician to win a libel action against a newspaper or broadcaster that is reasonably assiduous in checking its facts. Sullivan does not offer the media carte blanche to tell lies about politicians. The rationale underpinning Sullivan is firmly rooted in the notion of informed electoral consent to government. That consent is more likely to be informed if libel laws are skewed in favour of maximal dissemination of political information by making it difficult for politicians to win such litigation, even at the risk of allowing some false stories to enter the media arena, than by skewing them in favour of protecting politician's reputations by making it easier for them to win, for that would "chill" political speech by deterring the publication of information which could not be "proven" to a high degree of certainty. Sullivan was not presented by the Supreme Court as an "ideal" solution-but simply as the least of various irreconcilable constitutional evils.

Slightly modified versions of Sullivan have lately been adopted by the Australian High Court and the Indian Supreme Court, both of which have rooted the doctrine in provisions of their (supra-legislative) constitutions. 29 There seems to be little sympathy among English judges for the direct importation of Sullivan into domestic common law, and given that such reforms were omitted from the 1996 Act, it would seem inappropriate for the courts to take such an initiative.

However, there is now also a series of ECHR decisions on criminal libel which have indicated obiter that the civil law of defamation in the Convention's signatory states must draw some distinction between "political" and "private" libels.30 Plaintiffs must leap higher hurdles (although precisely how much higher the court did not say) to succeed in political actions. The ECHR's rationale in these dicta was pure Sullivan-political speech must enjoy greater freedom than non-political speech because its dissemination and discussion is essential to the maintenance of a responsive democratic polity, in which politicians can be held accountable to their electorates. for their behaviour.

As noted above, our courts have shown themselves responsive to nudges from the text of the Convention and the judgments of the European Court of Human Rights in the matter of the quantum of libel damages. There is no reason to assume they will not be similarly receptive to ECHR arguments on the issue of the remedial regime to be applied to political libels if and when the ECHR itself is presented with a Sullivan fact situation. Equally, following Lord Bingham MR.'s reasoning in Elton John v MGN,31 it is perfectly defensible in constitutional terms for the courts to develop English libel in ways that mirror ECHR requirements but which are reached entirely in response to changing judicial perceptions of domestic political requirements.

The obvious mechanism through which English courts could pre-empt ECHR mandated reform to domestic law would be to extend the defence of qualified privilege to political libels. Lord Lester is currently presenting the courts with that opportunity by raising an ECHR-inspired qualified privilege defence on behalf of The Sunday Times in the action initiated by Albert Reynolds, the former Taoiseach of Ireland.32 The defence was rejected by French J. at first instance, but will be the subject of an appeal by the Sunday Times early in 1997.

The qualified privilege defence is broadly analogous to the Sullivan rule: the burden of proof rests on the plaintiff to prove that factual claims in the story are false and that the story was motivated by "malice" on the publisher's part. These are difficult, albeit' not impossible, hurdles to surmount. Had the qualified privilege defence already been accepted as applicable to political Libels. Mr Hamilton would perhaps have thought more carefully about beginning his libel action at all. Indeed, one might hope that M.Ps, when faced with pecuniary temptations, would have thought more carefully about taking payments from commercial interests if they had known that newspapers could report such stories on the basis of reasonable suspicion rather than cast-iron certainty.33

If placed in this common law context, section 13 of the Defamation Act 1996 becomes much less objectionable from the electoral audience perspective. Are individual M.P. would be likely to waive the protection of Article 9 of the Bill of Rights only in circumstances where he or she knew the honesty of his or her conduct to be readily demonstrable. The libel writ could not serve as a gag on the public airing and analysis of political information. Section 13 would become no more than a procedural wrinkle rather than a substantive wound on our country's political physiognomy. It is a great shame that the defendant in Prebble did not raise the question of whether New Zealand common law now demanded the application of the qualified privilege defence to political libels. Had NZTV done so, the Article 9 question would have been relegated to subsidiary status, and might not even have been reached at all. By beginning a libel suit in the English courts against The Sunday Times for casting doubts on his honesty Albert Reynolds seems now to be presenting our judiciary with that opportunity in respect of English common law. It would seem highly desirable that the Court of Appeal now move in that direction-for it surely will not be too long before a media defendant convinces the ECHR that this would be the right approach.

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