Daniels v Griffiths: CA 27 Nov 1997

The claimant appealed against dismissal of his claim in defamation against the defendant. He was a prisoner convicted of rape and subject to life imprisonment. He sought parole, and said that the defendant had slandered him before the Parole Board.
Held: Parole Board proceedings are not part of any proceedings of a court, and so communications with the Parole Board are not protected by privilege from defamation actions. ‘It is clear . . that . . the defendant made a statement to the police to the effect that she was being harassed by the plaintiff and that a witness statement was taken from her. The contents of that witness statement and the details of any previous discussions leading to the taking of the witness statement would appear to be covered by the rule as to immunity.’


Hirst LJ, Swinton Thomas LJ, Sir Brian Neill


Gazette 17-Dec-1997, Times 02-Dec-1997, [1997] EWCA Civ 2836, [1998] EMLR 488




Criminal Justice Act 1991 Sch 5 Para 1


England and Wales


CitedGrovit and others v Doctor and others HL 24-Apr-1997
The plaintiff began a defamation action against seven defendants. Each had admitted publication but pleaded justification. The claims against the fourth to seventh defendants were dismissed by consent, and the third had gone into liquidation. The . .

Cited by:

CitedBuckley v Dalziel QBD 3-May-2007
There was a heated dispute between neighbours, culminating in some generous or perhaps over-generous pruning by the claimant of the defendant’s trees and shrubs on the boundaries. The defendants reported the matter to the police. Both Mr and Mrs . .
CitedWestcott v Westcott CA 15-Jul-2008
The defendant was the claimant’s daughter in law. In the course of a bitter divorce she made allegations to the police which were investigated but did not lead to a prosecution. The claimant appealed dismissal of his claim for defamation on the . .
Lists of cited by and citing cases may be incomplete.

Defamation, Prisons

Updated: 12 November 2022; Ref: scu.143235