It's also worth noting that UK libel laws are considerably more liberal than the US libel laws. A statement that would be fine in the US could result in a life-shattering judgment in the UK.
I remember reading a discussion on a UK site that a person could be convicted of libel in the UK even if the statement was true. (I am American, so dont base your defense on my comments.)
The glossed-over underlying issue in the linked article is that Britain's libel laws are notoriously hard to defend against. In the US, a comment has to be proven libelous; in the UK, you have to prove it isn't.
UK libel laws aren't that bad for situations like this — if he were sued in the UK, he could rely on the defence of honest opinion and I imagine he would prevail.
The libel and slander laws in the U.K. different than in the U.S. [0]:
> "English laws are much more favorable for someone looking to protect their reputation," says Jenny Afia, a lawyer in London who often represents people making libel and privacy claims.
> In American courts, the burden of proof rests with the person who brings a claim of libel. In British courts, the author or journalist has the burden of proof, and typically loses.
> "So you've got the rich and powerful shutting down and chilling speech which is critical of them," says Stephens.
I know for slander, in the USA you're allowed to say pretty much anything as long as it's true. The UK has much stricter laws against defamation. (In the US, the victim might sue for damages, but that's not the same as criminal charges.)
In the US, truthfulness of a statement is an affirmative defense to libel/defamation, but believe it or not, that is not the case everywhere. Specifically, it is not the case in the UK.
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