Extraneous non-privileged material

Curistan v Times Newspapers Ltd QBD TLR 10 May

Section 15(1) of the Defamation Act 1996 confers qualified privilege on fair and accurate reports of proceedings in Parliament. The Times published a report of a speech made by Peter Robinson MP in Parliament, which was accompanied by other material. Was the privilege which attached to the report of the speech lost because of the addition of the extraneous non-privileged material contained in the article reporting it? The answer depended on three considerations: