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[1998] VSC 2
Supreme Court of Victoria
1998-07-24
CHERNOV, J.
Original judgment source is linked above.
interlocutory - Alleged defamatory publication - Disclosure of journalist's source - Newspaper rule - Application in interlocutory proceeding -Whether necessary in the interests of justice - Relevance - Aura of authenticity.
"INTRUDERS have broken into the Australian Securities Commission's Melbourne headquarters to spy on documents at the centre of the country's biggest corporate probe.
The raiders by-passed an array of lift security devices and electronically coded locks and sensors.
They ignored money, valuables and unlocked doors and made for the `Coles Myer' room.
The locked room contains sensitive documents about the notorious 1990 Yannon transaction, which effectively transferred an $18 million loss from Coles Myer's former chairman, Solomon Lew, to the retailing giant.
The weekend break-in - undetected until commission staff arrived for work yesterday morning - came as the corporate watchdog considered charges after a two-year investigation.
A source close to the investigation said: `The thieves knew what they were doing. They must have been good to get around the security system.'
The break-in was hushed up to the extent that some people central to the two-year investigation did not know about it last night. ...
Corporate espionage is suspected as the motive for the weekend break-in.
A commission spokeswoman said it was not known whether anything was taken.
But sources said the intruders could easily have photographed documents or photocopied them on commission machines nearby.
The Yannon transaction is the largest file the ASC is working on.
Sources said the raiders broke a window on the ground floor of the Commercial Union building at 485 La Trobe St, where the ASC's Melbourne office occupies five floors.
The high-rise offices were reached although a security key is needed to operate the lift.
The intruders then by-passed the electronic security system on each floor, which requires a six-digit code to be punched into a keypad, and entered the commission offices.
Sensors on each floor connected directly to a security firm failed to detect the break-in.
Sources said the intruders ignored money, valuables and unlocked doors, concentrating on locked drawers.
It was suggested they knew what they were looking for - the keys to the Coles Myer room.
A spokesman for the Australian Federal Police confirmed last night they were `undertaking initial inquiries' about a reported incident at the commission offices'.
`As these inquiries are ongoing it would be inappropriate to make further comment at this time,' he said."
(a) the defendant published the relevant material with the deliberate intention of thereby injuring the plaintiff;
(b) the defendant knew or ought to have known that the imputations conveyed by the relevant material were untrue and without foundation;
(c) the publication was made recklessly by the defendant who did not care whether the imputations thereby conveyed about the plaintiff were true or false;
(d) the defendant failed to make any proper enquiry to ascertain whether any material was true.
(a) Material in the articles which relied on sources that were "close to the investigation", was wrong. For example, the articles reported that the raiders gained entry into the room containing the Yannon-Coles Myer Ltd documents, whereas the reality was that they did not gain such entry. (I have already mentioned that this error was recognised by the defendant which printed the fact that the raiders did not enter the Yannon-Coles Myer Ltd room, on 28 May 1997.)
(b) The defendant's pattern of conduct in the interlocutory stages, namely, whenever it was pressed to reveal the sources, it refused to do so and ultimately, under threat of a strike out, abandoned its defence of qualified privilege.
(c) The statements by Blunden during the radio interview were inconsistent with the articles.
(d) There is some divergence between the notes and the articles.
"The point is that there is a paramount interest in the administration of justice which requires that cases be tried by courts on the relevant and admissible evidence. This paramount public interest yields only to a superior public interest, such as the public interest in the national security. The role of the media in collecting and disseminating information to the public does not give rise to a public interest which can be allowed to prevail over the public interest of a litigant in securing a trial of his action on the basis of the relevant and admissible evidence. No doubt the free flow of information is a vital ingredient in the investigative journalism which is such an important feature of our society. Information is more readily supplied to journalists when they undertake to preserve confidentiality in relation to their sources of information. It stands to reason that the free flow of information would be reinforced, to some extent at least, if the courts were to confer absolute protection on that confidentiality. But this would set such a high value on a free press and on freedom of information as to leave the individual without an effective remedy in respect of defamatory imputations published in the media." "The liability of the media and of journalists to disclose their sources of information in the interests of justice is itself a valuable sanction which will encourage the media to exercise with due responsibility its great powers which are capable of being abused to the detriment of the individual. The recognition of an immunity from disclosure of sources of information would enable irresponsible persons to shelter behind anonymous, or even fictitious, sources."
" ... a practice is recognized of refusing to compel such a defendant to disclose the name of the writer of an article complained of as a libel or of the sources of information he has relied upon. The foundation of the rule is the special position of those publishing and conducting newspapers, who accept responsibility for and are liable in respect of the matter contained in their journals, and the desirability of protecting those who contribute to their columns from the consequences of unnecessary disclosure of their identity."
"In effect, the courts have acted according to the principle that disclosure of the source will not be required unless it is necessary in the interests of justice. So, generally speaking, disclosure will not be compelled at an interlocutory stage of a defamation or related action and even at the trial the court will not compel disclosure unless it is necessary to do justice between the parties."
(a) The source of the information on which the articles were based (and the reporters' notes) are relevant to the issues of damages and identification.
(b) In the articles themselves, the defendant created an aura of authenticity by stating that it had sound sources for the material and it would be incongruous and unjust to allow it to shield behind the newspaper rule until trial. In this regard, the defendant relies, in particular, on what the High Court said in John Fairfax & Sons Ltd v. Cojuangco, supra, at p.358.
(c) The defendant would have the tactical advantage of being able to choose when it identified the source. Similarly, the plaintiff would not know how to open its case before the jury.
(d) The notes containing the blacked-out parts are difficult to decipher because of the deletions. It is necessary to read the deleted parts to make sense of much of the remainder.
(e) The Court should exercise its discretion in the plaintiff's favour, having regard to the conduct of the defendant during the interlocutory process, particularly its failure to produce the documents sought.
"No court may require a person to disclose, nor is any person guilty of contempt of court for refusing to disclose, the source of information contained in a publication for which he is responsible, unless it be established to the satisfaction of the court that disclosure is necessary in the interests of justice or national security or for the prevention of disorder or crime."
(a) Where an applicant complains of a defamatory publication in a newspaper, a Court will refuse to order preliminary discovery if it appears that the applicant has an effective remedy against the newspaper or journalist without the necessity for making such an order.
(b) But where it appears that the newspaper and journalist may plead statutory qualified privilege (and thereby avoid liability) a judge is entitled to exercise his discretion to make the order sought for preliminary discovery if the newspaper and journalist do not relinquish that defence and the judge considers that the defence might prevail.
I certify that this and the 18 previous pages are a true copy of the reasons for judgment of Chernov, J. of the Supreme Court of Victoria delivered on 24 July 1998.
Lew
Herald & Weekly Times Ltd [1998] VSC 2