DefamationLibelCourt of Appeal (England)

Youssoupoff v Metro-Goldwyn-Mayer Pictures Ltd.

(1934) 50 TLR 58119341 min read
The case in brief30-second read
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.
Principle
A permanent, recorded medium such as film falls within the libel category, given its durable, permanent form.
Cite this

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

  1. 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.

Exam use

How to use it in an answer

  • 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.

Cite this

Citation

Youssoupoff v. Metro-Goldwyn-Mayer Pictures Ltd. (1934) 50 TLR 581

Reported: (1934) 50 TLR 581. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.