The recent decision in Noel Clarke v Guardian News & Media (GNM) marks a dramatic close to a high-profile libel battle. On 22 August 2025, Mrs Justice Steyn handed down a 224-page landmark judgment dismissing Clarke's £70 million claim in its entirety. After six weeks of evidence, including live testimony from more than a dozen accusers, senior Guardian journalists, and Clarke himself, the judge concluded that GNM's multi-part investigation into allegations of sexual misconduct and bullying was both substantially true and published in the public interest.
The case began in April 2021, when The Guardian published its first article quoting 20 women who worked with Clarke and alleged unwanted sexual contact, covert filming and workplace bullying. Over the next two years, Clarke issued a strongly worded denial, brought defamation and data protection proceedings, and quantified his loss at more than £70 million. Pre-trial battles included Clarke's applications to strike out GNM's defence for alleged evidence destruction and to add a last-minute conspiracy claim, both of which were rejected. The Court of Appeal upheld those rulings, clearing the path for a six-week trial in the High Court which took place in March and April this year.
In essence, in her judgment, Mrs Justice Steyn found that Mr Clarke had, over a prolonged period, pursued a course of sexually inappropriate conduct and workplace bullying that matched, in all material respects, the conduct described in the Guardian's reporting. The judge characterised Clarke's oral evidence as evasive and internally inconsistent, holding that his categorical denials were “wholly lacking in credibility”. By contrast, she described the Guardian's witnesses many of whom testified about separate incidents occurring years apart as measured, mutually corroborative and supported by contemporaneous documentation. Clarke's efforts to cast doubt on their motives were dismissed as speculative and unsubstantiated, and the court held that he had, on several occasions, misrepresented key facts both in correspondence and in his pleadings.
Crucially, the court emphasised that the truth defence does not require proof beyond reasonable doubt; instead a mosaic of corroborated testimony, contemporaneous messages, and industry witnesses was sufficient. Even if GNM had fallen short on truth, its rigorous pre-publication process, interviewing more than 70 sources, seeking comment from Clarke at every stage, and retaining a detailed editorial paper-trail satisfied the public interest test. The judge praised the investigation as a template for public interest journalism.
The lessons here are clear. For publishers, painstaking fact-gathering and scrupulous documentation create a double layer of protection: they fortify the truth defence and independently satisfy the public interest requirement. For potential claimants, the decision is a cautionary tale: where contemporaneous evidence and first-hand testimony line up against you, litigation may compound reputational damage rather than repair it. The courtroom spotlight is unforgiving, and any attempt to navigate it without full disclosure or with speculative attacks on witnesses is likely to fail.
Above all, the ruling underscores that process is protection, and it reaffirms the central role of investigative journalism in a democratic society. By upholding the value of thorough editorial practice and public interest reporting, the High Court has set a powerful precedent, one that will encourage journalists to pursue difficult stories and remind claimants of the high bar for challenging well founded investigations.
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