End of round 1 in Frank Warren v Chris Eubank Jr defamation claim

In Warren v Eubank [2025] EWHC 828 (KB), which must be one of the shortest media law judgments ever handed down, Mr Justice Jay reminded libel practitioners why a simple approach to determining meaning is often best.

Frank Warren, the boxing promoter, who is no stranger to the libel courts, has sued the professional boxer, Chris Eubank Jr.   The action relates to a statement during a live press conference, broadcast on Sky Sports, in which Mr Eubank said Mr Warren had “been lying and cheating his way through boxing for the last couple [of] decades”.

Mr Warren contended that these words, which formed part of a longer statement, meant:-

"the Claimant is a liar and a cheat: a man who has been guilty throughout the past 20 years of his practice as a boxing promoter of having consistently, serially and routinely acted in ways that are seriously deceitful, dishonest and unethical, and of having defrauding those boxers he promotes along with the other parties he deals with throughout the sport."

Mr Eubank disagreed.  He argued that the words meant:-

"The Claimant is guilty of repeated dishonest and unethical conduct in his practice as a boxing promoter over the past two decades."

Cautioning the parties against over-analysis, Jay J found that Mr Eubank’s words meant that Mr Warren had “frequently been guilty of lying and cheating in his business dealings as a boxing promoter”.  Readers will note the similarity between this meaning and the actual words used by Mr Eubank.  In this case, Jay J considered that there was no need to gloss or provide a synonym for “lied” or “cheat”.

The succinct and uncomplicated meaning found by Jay J in this case can be contrasted with some other cases where the Court has found a baroque or ornate meaning which did not occur to either party.  This judgment therefore serves as a salutary reminder that, when advancing a defamatory meaning in a libel claim, simplicity is sometimes best.  After all, the hypothetical reader is only an ‘ordinary’ (reasonable) person who, it might be thought, would be unlikely to take a complex meaning from words which very much speak for themselves.