Meaning, repetition, and Chase levels in a celebrity libel claim

In Belafonte v News Group Newspapers Ltd [2026] EWHC 273 (KB), Mrs Justice Collins Rice determined the single natural and ordinary meaning of a short Sun article concerning Stephen Belafonte and allegations made by his former wife, Melanie Brown, known as Mel B. The parties agreed that the publication conveyed factual allegations and was of defamatory tendency at common law. The dispute was therefore directed to the level of meaning, including whether the article conveyed guilt level allegations or lower Chase level meanings.

The decision provides a useful illustration of how the court approaches meaning in a short item of celebrity gossip, and how the repetition rule operates where a publisher reports allegations attributed to a third party or to anonymous sources. It is also a practical reminder that meaning is determined by reference to the ordinary reasonable reader reading quickly, impressionistically and in context, not by close lawyerly dissection.

Background and the words complained of

The claimant, Mr Stephen Belafonte, is a film and television producer, director and talent manager who lives in the United States and regularly visits England and Wales for professional and personal reasons. He was formerly married to singer Melanie Brown. The defendant, News Group Newspapers Limited, publishes The Sun. The claim concerned an article published online on 27 June 2024 and in print on the following day. The parties agreed that the differences between the two versions were not material for present purposes.

The article was headed “MEL’S PAIN”. In substance, it said that Mr Belafonte faced being questioned by UK police over harassment claims made by Ms Brown, that she was still “living in fear” of him after claiming he beat and abused her during their marriage, that she had a restraining order against him in the United States, and that during a visit to Britain a drone was flown over her home and a messenger was sent to serve proceedings despite the writ already being with her solicitor. It concluded with the statement: “Mel believes that it amounted to harassment by Belafonte.”

The legal framework

The court applied the familiar principles governing determination of meaning, including the guidance set out by Nicklin J in Koutsogiannis v Random House Group Ltd [2019] EWHC 48 (QB). Meaning is determined by reference to the hypothetical ordinary reasonable reader. Such a reader is not naive, but nor is he unduly suspicious. He can read between the lines and indulge in a certain amount of loose thinking, but he is not avid for scandal. The court must avoid over elaborate analysis, read the publication as a whole, take account of context and mode of publication, and is free to choose the correct meaning provided it is not more injurious than the claimant’s pleaded meaning.

The parties agreed that the case concerned factual allegations. The judge therefore approached the issue through the familiar Chase spectrum: level 1, guilt; level 2, grounds to suspect guilt; level 3, grounds to investigate whether the claimant is guilty. The judgment also emphasised that these are better understood as points on a spectrum than as rigid boxes.

A  feature of the case was the repetition rule. The fact that a publication reports allegations made by others does not, of itself, make the sting any less defamatory. A hearsay allegation is treated as equivalent to a direct allegation for the purposes of libel. But the court also stressed, consistently with Brown v Bower [2017] EWHC 313 (QB) and Hemming v Poulton [2025] EWCA Civ 1494, that context remains critical. A repeated allegation may be adopted at guilt level, or it may be presented more provisionally.

The judge also proceeded on the basis that the article had to be read as a whole, in accordance with the contextual approach often referred to through Charleston v News Group Newspapers Ltd [1995] 2 AC 65. That mattered here because, although Mr Belafonte wished to complain only of what the article conveyed about matters after the marriage, the ordinary reader would necessarily understand those matters against the background of the article as a whole.

The parties’ proposed meanings

Mr Belafonte’s pleaded meanings were set out by the judge in the following terms:

“a. he is guilty of having harassed Ms Brown in the United States;
and
b. he cynically exploited a visit to England with his and Ms Brown’s child to further harass Ms Brown in this country, by flying a drone over her home, and by gratuitously causing her to be visited in person by a process server despite Ms Brown being represented by lawyers, conduct which intimidated her, and means that he is guilty of the criminal offence of harassment.”

The judge recorded immediately after that: “These are Chase level 1 meanings: imputations of guilt in each case.”

The defendant’s pleaded meanings were also set out expressly in the judgment:

“a. there are grounds to investigate whether the Claimant beat and abused his ex-wife, Mel B, during their marriage [Chase level 3]; and
b. there are grounds to suspect that, during a visit to the UK, the Claimant caused a drone to be flown over Mel B’s home and sent a messenger to serve a legal writ on her, even though her solicitor already had a copy [Chase level 2], and there are grounds to investigate whether such acts amounted to harassment of Mel B. [Chase level 3]”

Those competing meanings framed the central dispute. The claimant argued that the article, read fairly and applying the repetition rule, straightforwardly presented him as a perpetrator and Ms Brown as a victim, with both the historical and recent allegations being published at guilt level. The defendant argued that the article did not adopt the allegations in that way, that it signalled some distance from the historical claims, and that the more recent matters were presented in a more provisional and investigative way.

The court’s approach to the ordinary reasonable reader

A feature of the judgment is the judge’s emphasis on the genre and presentation of the article. She said that, when first read, the piece registered as “a brief item of celebrity gossip” which an ordinary reasonable Sun reader would absorb “in a matter of seconds before moving swiftly on”. That observation informed the whole analysis. The court stressed that the ordinary reader of such a piece is being entertained, not invited to perform a close evidential or legal analysis.

The court also attached significance to the headline and image. The headline “MEL’S PAIN” directed the reader immediately to Ms Brown and her distress. The accompanying image, coupled with the article’s presentation, framed the story as one about her experience of trouble and fear said to be caused by her former husband. The judge concluded that the overarching message of the piece was that Ms Brown “lives in fear” of Mr Belafonte, and has cause to do so.

That overarching message was then analysed by the court as being supported by two salient pieces of information about Mr Belafonte: first, the restraining order in the United States, read against the background of historic allegations; secondly, the more recent events in the United Kingdom involving the drone and the process server.

Meaning 1: harassment in the United States

In relation to the first limb, the judge placed weight on the article’s reference to a current restraining order in the United States. An ordinary reader would not analyse the legal basis on which such an order might have been obtained. Rather, the restraining order functioned as a powerful scene setter. In context, it conveyed that Ms Brown had needed court protection from Mr Belafonte because he had been causing her trouble. The judge rejected as too lawyerly the suggestion that a reader would have in mind fine distinctions about possible bases for the order.

The court also held that the headline term “harassment” would be understood non technically and compendiously. The ordinary reasonable reader would take it as covering any unwanted, persistent, intimidating, intrusive or otherwise harmful course of conduct in the context of a former intimate relationship. The reader would not concern himself with the differences between harassment, bullying, abuse or beating. He would instead take away a broad impression of targeted and unjustifiable conduct of some seriousness.

The judge’s conclusion on this first meaning was:

“The Claimant is guilty of having harassed Ms Brown in the USA. [Chase level 1]”

That was therefore a guilt level meaning.

Meaning 2: the United Kingdom allegations

The second aspect of the article concerned the more recent UK events. Here the judge considered that the piece was presented differently. The recent matters formed “the latest story”, were sharper in detail, and had the quality of a developing situation. Ms Brown was said to be fearful and distressed and the police had been approached, but the article did not make clear what the next steps or outcome would be. The judge regarded this part of the publication as more provisional.

The article reported the drone and process server incidents baldly from the source, so the reader would have no reason to doubt that the incidents themselves had occurred. But the connection between those events and Mr Belafonte was not equally strong in each case. The process server had an obvious link to him because the documents concerned his lawsuit. By contrast, the article made no direct connection between him and the drone other than Ms Brown’s generic fears about him. The judge also observed that ordinary readers are not familiar with the rules of service and would not necessarily regard personal service as inevitably gratuitous or unnecessary in itself.

Against that background, the reader would understand why Ms Brown was anxious and why she associated those events with Mr Belafonte. But the judge was not persuaded that the article itself adopted those allegations at guilt level. It was too circumspect and provisional for that, including because any active police interest remained unconfirmed. The article did, however, plainly advance the process server, the drone and Mr Belafonte’s presence in the United Kingdom as grounds to suspect that Ms Brown was right in thinking she was still the object of harassment by him.

The judge’s final formulation of this second meaning was:

“There are grounds to suspect that, during a subsequent visit to the UK, the Claimant:
(a) caused a drone to be flown over Ms Brown’s home; and
(b) caused a process-server to visit her unnecessarily;
and there are accordingly grounds to suspect the Claimant of harassing Ms Brown in the UK in these circumstances.
[Chase level 2]”

This was therefore a suspicion level meaning, not guilt.

What the court rejected

The judge expressly rejected the more elaborate aspect of the claimant’s UK case, namely the allegation that he had cynically exploited the child contact visit in order to continue harassing Ms Brown. That was held to be an extrapolation beyond what an ordinary reasonable reader would take from the article. A reader would understand that Mr Belafonte did not need to be physically present in the United Kingdom to deploy either a process server or a drone, and would not pursue speculation about his mindset or motive at that level of detail in the context of a brief gossip item.

That rejection is important because it shows the limit of the court’s willingness to infer scandal. Although the ordinary reader may indulge in a degree of loose thinking, the court will not attribute a detailed narrative of cynical scheming or motive unless the publication itself supports it.

Comment

The decision is a practical reminder that meaning issues remain highly context sensitive. A short, sensationally presented article may still convey a serious guilt level sting, particularly where the publication uses background material to set the scene and presents the claimant as the explanation for another person’s fear. That is what happened here in relation to the United States allegation.

At the same time, the judgment shows that the repetition rule does not operate mechanically. The fact that a newspaper repeats allegations made by others does not reduce the defamatory sting merely because they are attributed. But context may still show that some allegations are being advanced as suspicion rather than as proved fact. Here the historical material and restraining order were enough to produce a Chase level 1 meaning, whereas the more recent UK matters remained at Chase level 2 because the article was more provisional and the evidential connections were less direct.

The judgment also illustrates the court’s approach to the ordinary reasonable reader in the tabloid context. The reader of a brief celebrity gossip item is not engaging in precise legal analysis. He reads quickly, takes away broad impressions, and absorbs headline, imagery and context as part of the message. That matters particularly in cases where a publisher seeks to argue that attributed allegations should be understood with caution.

Further Reading

• A Guide to Determination of Meaning in Defamation Cases
• The Honest Opinion Defence in English Defamation Law
• Defamation Defences