판결 이유
Responsible journalism on matters of public interest could provide a defence to defamation (the Reynolds privilege). A non-exhaustive list of factors ('the Reynolds factors') were relevant to whether the defence was made out.
사실관계
Albert Reynolds, the former Irish Taoiseach, sued The Sunday Times over an article about his resignation. The newspaper argued it was protected by qualified privilege as responsible journalism on a matter of public interest.
판결 요약
The House of Lords developed a new form of qualified privilege for responsible journalism on matters of public interest. Lord Nicholls set out ten non-exhaustive factors for assessing whether the defence applied, including the seriousness of the allegation, steps taken to verify, and whether comment was sought from the claimant.
주요 인용문
"The court should have particular regard to the importance of freedom of expression. The press discharges vital functions as a bloodhound as well as a watchdog."
— Lord Nicholls
후속 처리
Replaced by the statutory public interest defence in s.4 Defamation Act 2013, though the Reynolds factors remain relevant to applying s.4.