Brief Fact Summary. False and malicious information is published in a county newspaper about a boiler maker business.
Synopsis of Rule of Law. General damages need to be proven in order to receive compensation for false and malicious statements.
Issue. Whether special damages need to be proven at trial to receive compensation for false and malicious publication of Plaintiff’s business affairs?
Held. (Justice Bowen). No. Plaintiffs are not required to prove special damages in order to receive compensation for false and malicious publication of its business affairs. Plaintiffs are only required to show general damages. Defendant’s appeal is dismissed.
Discussion. The court seems to reserve the requirement of proving special damages to more complex defamation cases. The opinion, however, fails to outline which cases would require a showing of special damages.