Youssoupoff v. Metro-Goldwyn-Mayer Pictures Ltd.

(1934) 50 TLR 581Court of Appeal (England)1934Law of Torts

Rule established

A permanent, recorded medium such as film falls within the libel category, given its durable, permanent form.

Facts

The defendant produced and distributed a film containing a scene falsely suggesting a defamatory imputation about the plaintiff, Princess Youssoupoff. The plaintiff sued for defamation. The specific question concerned the correct classification of a defamatory statement conveyed through film.

Issue

Whether a defamatory imputation conveyed through a film constitutes libel or slander, given the medium's recorded, visual character.

Held

Film, as a permanent, recorded, and durable medium, falls within the libel category. This classification followed from film's fixed, lasting character, comparable to other permanent forms of publication. The claim proceeded on this basis, with libel's actionable-per-se character applying rather than slander's special damage requirement.

Ratio Decidendi

A defamatory statement conveyed through a permanent, recorded medium, including film, is classified as libel rather than slander, given the medium's durable, lasting character and its capacity for wide, repeated dissemination.

How to use it in an exam

Key line: "In Youssoupoff v Metro-Goldwyn-Mayer Pictures Ltd (1934), the court held that a defamatory imputation conveyed through film constitutes libel, given the medium's permanent, recorded form."
Use to extend the libel/slander distinction to modern recorded media, illustrating the principle's flexibility beyond mere print.

Source

Source: (1934) 50 TLR 581

This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.

Cited in study notes

Law of TortsDefamation Libel and SlanderConfirms that permanent, recorded media fall within the libel category, given their durable form