RATCLIFFE V. EVANS
2 Q.B. 524 (1892).
NATURE OF THE CASE: This was an action for tortious injury to a business by publication.
FACTS: Ratcliffe (P) and his father were in business as an engineer and boiler maker
under the name Ratcliffe and Sons. P operated the family business after his father died.
Evans (D) published an article stating that the business had ceased to exist. P sued under
false and malicious publication. The jury found that the statement was purposefully made to
cause damages to P. P was awarded a judgment. The proof of loss in damages was from a
general loss in business. D appealed; P was unable to prove special damages.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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