Knupffer v London Express Newspaper Ltd. [1944] AC 116

Key Point

  • In general, a statement about a group does not entitle group members to bring individual claims of defamation


  • The respondents published a newspaper article alluding to the fact that the Young Russia Party in the UK was collaborating with Hitler
  • The appellant, a Russian resident in the UK, sued for damages in libel
  • The Court of Appeal held that the words did not refer to the appellant, who then appealed to the House of Lords

Held (House of Lords)

  • Appeal dismissed; the appellant was not entitled to bring a claim for defamation

Viscount Simon LC

  • An individual can bring a claim where the group is small enough and where “… the language used in reference to [the] limited class may be reasonably understood to refer to every member of the class, …every member may have a cause of action”: p. 119

Lord Atkin

  • A class of people can only sue where “the words would reasonably be understood as published of each member of the firm or each trustee or each tenant”: p. 122
  • “The reason why a libel published of a large or indeterminate number of persons described by some general name generally fails to be actionable is the difficulty of establishing that the plaintiff was, in fact, included in the defamatory statement, for the habit of making unfounded generalisations is ingrained in ill-educated or vulgar minds, or the words are occasionally intended to be a facetious exaggeration”: p. 122


  • This case reaffirms the rule that the alleged defamatory statement must refer to the claimant and that an ordinary reasonable reader approach is preferred when determining whether the words in the statement refer to the claimant