Iqbal (Appellant) v Geo TV Limited (Respondent)

Case summary

Case ID

UKSC/2025/0011

Parties

Appellant(s)

Salman Iqbal

Respondent(s)

Geo TV Limited

Issue

Did the Court of Appeal (“CA”) err in allowing the appeal and entering summary judgment for the defendant to a libel action? In particular: (1) Section 15(3) of the Defamation Act 1996 says that qualified privilege does not apply to “…matter which is not of public interest and the publication of which is not for the public benefit.” Did the CA err in treating these two conditions as consecutive for the claimant to establish, rather than cumulative for the defendant to establish? (2) Did the CA err in excluding contextual matters pursuant to s.15(3)? (3) Did the CA err in determining that a live broadcast is capable of amounting to a ‘report’ for the purposes of s.15(1)?

Facts

This case involves two broadcasters and two major political parties in Pakistan. The two rival broadcasters are ARY Digital Network (“ARY”) and Jang Group. ARY is responsible for Urdu language TV channels. The claimant/appellant, Mr Salman Iqbal, is the founder and president of ARY. The defendant/respondent (“Geo”) is an English registered company forming part of the Pakistan-based Jang media group, which produces the Urdu language news channel GEO News. Geo is responsible for broadcasts of GEO News within the UK. On 19 May 2022, the Pakistan Muslim League (Nawaz) (“PML-N”) political party held a rally in Pakistan, at which its Vice-President, Maryam Nawaz Sharif, gave an address. Ms Sharif’s speech engaged in a wide-ranging attack on Imran Khan, former Prime Minister of Pakistan and founder of a rival political party, Pakistan Tehreek-e-Insaf (“PTI”). The words which Mr Iqbal complains were libel were spoken during the closing part of Ms Sharif’s speech. Ms Sharif made several serious accusations against Mr Iqbal and alleged that he had participated in a corrupt relationship with Imran Khan. This event was covered on GEO News by way of live broadcast in the UK. Spoken or written summaries of those words appeared subsequently in eleven news bulletins broadcast on GEO News. Mr Iqbal issued proceedings in libel in relation to the live broadcast and the eleven subsequent news bulletins broadcast by Geo in England and Wales. Geo applied for summary judgment on the basis that Mr Iqbal had no realistic prospect of resisting Geo’s complete defence under s. 15, Defamation Act 1996. The High Court judge refused summary judgment on the basis that Mr Iqbal had a realistic prospect of success on two issues, namely whether the broadcasts complained of satisfied section 15(3) and whether they were published maliciously. The Court of Appeal allowed Geo’s appeal and entered summary judgment for Geo. Mr Iqbal now appeals to the Supreme Court.

Date of issue

21 January 2025

Case origin

PTA

Appeal

Justices

Lord Hodge

Lord Leggatt

Lord Stephens

Permission to Appeal

Permission to Appeal decision date

7 April 2025

Permission to Appeal decision

Refused

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