Watt v. Longsdon

1 K.B. 130 (1930)

Facts

Watt (P) sued Longsdon (D) for defamation on three counts. P was the managing director at Casa Blanca in Morocco of the Scottish Petroleum Company, Ld. D was a director of the company in England. The company went into voluntary liquidation in November 1927, and D was appointed the liquidator. Browne was the manager of the company at Casa Blanca. The chairman of the board of directors in England was Singer. While P was in Casa Blanca and his wife was in England, Browne in Casa Blanca wrote to D in England. In the letter Browne claimed that P owed a large sum of money to spirit merchants and that he doubted they would be paid, that P's maid was P's mistress and that P's mistress was an old woman, stone deaf, almost blind, with dyed hair, that these facts were true as the maid knew facts about Mrs. Watt and the cook verified that the maid spent nights with P and that both the cook and the maid said that P did receive dancing girls, etc., in his flat. Browne stated that he was quite certain that orgies took place and that P is a beast and a perjurer and that P is vicious and gets into uncontrollable passions brought on by drink and his own inherent vices. (Browne also stated that there were many more bad things about P). D sent the letter to Mr. Singer, the chairman of the board of directors in England. D replied to Browne asking for corroboration by sworn statement of all these happenings even if it was necessary to bribe the women to do such and if only a matter of a few hundred francs. Before getting any sworn statement or any other corroboration of the allegations contained in Browne's original letter, D showed the original letter to P's wife, with the result that P and his wife separated, and the wife instituted proceedings for divorce. P sued for libel, alleging publication by D (a) to Singer and (b) to P's wife and publication of D's own letter to Browne. D claimed that the publications were privileged. The trial judge ruled that the three publications complained of were all made on privileged occasions and that there was no evidence of malice to go to the jury. He, therefore, gave judgment for D. P appealed.